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Regulation and Compliance: Ready for Review

Independent Banker

This is particularly true for community banks preparing to undergo their next regulatory safety and soundness or compliance examination. The better prepared, the less likely they are to run afoul of the continually shifting regulations. in Kent, Ohio. Be aware of existing or emerging risk concerns.

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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. While several states oppose the preemption of state usury laws in the context of bank/nonbank partnerships, federal banking regulators have taken a different stance.

Utah 78
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OppFi files complaint to block “true lender” challenge by California Department of Financial Protection and Innovation

CFPB Monitor

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.) Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado.