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California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank

CFPB Monitor

The DBO indicated that it “is investigating whether LoanMart’s role in the arrangement is so extensive as to require compliance with California’s lending laws. Thus, both the OCC and FDIC have adopted regulations rejecting the Second Circuit’s Madden decision. The FDIC has not yet proposed a similar rule.

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