Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule
CFPB Monitor
SEPTEMBER 9, 2020
Our letter draws on Ballard Spahr’s two-plus decades of experience in representing banks and savings associations (“Banks”) in establishing lending programs (“Bank-Agent Programs”) where a Bank obtains substantial assistance from a fintech or other non-Bank company (an “Agent”) to offer Bank loans to consumers or small businesses. .
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