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Colorado Settlement Provides a Possible Path Forward for Certain Bank-Fintech Online Lending Partnerships

CFPB Monitor

We have previously blogged about the lawsuits filed by the Colorado Attorney General against fintechs Avant and Marlette Funding and their partner banks WebBank and Cross River Bank. Supreme Court, a Colorado appellate court (after any chance for appeal has run) or the FDIC adopts a “true lender” test that differs from the safe harbor).

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OppFi files complaint to block “true lender” challenge by California Department of Financial Protection and Innovation

CFPB Monitor

Given such continuing threats, non-bank participants would be well-advised to revisit their vulnerability to “true lender” challenges and their compliance with state licensing laws. Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado. The DFPI is not alone in asserting a “true lender” claim.

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Who were ICBA’s Top Lenders of 2022?

Independent Banker

Using FDIC data for 2021, we calculated a lender score out of 100 for each community bank. Self Financial handles the technology, including access to online accounts and an app, as well as marketing aspects of the program, and Lead Bank provides the compliance and access to the banking system. First Colorado National Bank.