Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule
CFPB Monitor
SEPTEMBER 9, 2020
As our comment letter explains, in a typical Bank-Agent Program, an Agent may serve as marketing and servicing agent to a Bank that charges interest on its loans nationwide at the rates allowed by federal banking law and the law of the state where the Bank is located. Citibank (South Dakota), N.A., 12 U.S.C. ยง
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