Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule
CFPB Monitor
SEPTEMBER 9, 2020
Ballard Spahr LLP has submitted a comment letter to the OCC in support of its proposed rule , “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”). Three virtually identical Federal Interest Statutes govern interest that may be charged by Banks: Section 85 of the National Bank Act (“NBA”), 12 U.S.C. §
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