Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule
CFPB Monitor
SEPTEMBER 9, 2020
1831d(a) (“Section 27(a)”), which governs the interest charges of state-chartered FDIC-insured banks. The recharacterization threat also diminishes both the opportunity for innovation in lending products and the availability of credit, especially for consumers with risker credit profiles. Citibank (South Dakota), N.A.,
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