Jeff For Banks

DECEMBER 10, 2023

Although one might argue that First Citizens BancShares of Raleigh is a SIFI as it climbed to the 19th largest in the country with its Silicon Valley Bridge Bank acquisition from the FDIC, and that the FDIC designated SVB as systemically important. First Citizens Bank was founded in North Carolina in 1898 as the Bank of Smithfield.

Fresno 103

Fresno North Carolina Raleigh FDIC 103

CFPB Monitor

SEPTEMBER 10, 2020

Thereafter, “using its existing lending operations and personnel, LoanMart commenced ‘marketing’ and ‘servicing’ auto title loans purportedly made by CCBank, a small Utah-chartered bank operating out of Provo, Utah.” Thus, both the OCC and FDIC have adopted regulations rejecting the Second Circuit’s Madden decision.

Utah 78

Utah California FDIC West Virginia 78

CFPB Monitor

MARCH 15, 2022

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.

California 78

California Innovation Utah West Virginia 78