OppFi files complaint to block “true lender” challenge by California Department of Financial Protection and Innovation
CFPB Monitor
MARCH 15, 2022
The OCC’s attempt to provide a clear bright line test for determining when a bank is the “true lender” in a bank-model program through a regulation was overturned by Congress under the Congressional Review Act.) In addition to “true lender” threats, non-bank participants in bank-model programs will continue to face state licensing threats.
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