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. Citibank (South Dakota), N.A., We urge the FDIC to propose and adopt a true lender rule that mirrors the OCC’s Proposed Rule. As the Supreme Court instructed in Smiley v.
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