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California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank

CFPB Monitor

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
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Update on state small business commercial financing disclosure laws

CFPB Monitor

Around the nation, regulators are preparing to implement and enforce new consumer-like disclosure laws for small business commercial finance providers. New York regulators have yet to issue final regulations implementing the state’s Commercial Finance Disclosure Law (CFDL), which went into effect on January 1, 2022.

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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.) In addition to “true lender” threats, non-bank participants in bank-model programs will continue to face state licensing threats.

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Utah’s new regulatory sandbox

CFPB Monitor

Utah Governor Gary Herbert signed H.B. Regulatory sandboxes are laboratories for the development of innovative technologies in an environment that is free from onerous government restrictions. The sponsor of Utah’s legislation, Rep. The program will be administered by the Utah Department of Commerce (the Department).

Utah 60
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SoFi’s Bank Charter Has Almost No Chance, Former SEC Chairman Says

Bank Innovation

The charter, submitted to the State of Utah last June, would give the online lender the ability to collect deposits insured by the […].

Utah 170
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CFPB finalizes product sandbox proposal and changes to trial disclosure, no-action letter policies; discloses plans to propose interpretive letter program

CFPB Monitor

In addition, the CFPB has announced the creation of the American Financial Innovation Network (ACFIN) to facilitate coordination between the CFPB, other federal regulators, and state regulators and the CFPB’s issuance of the first NAL under the revised NAL Policy. Product Sandbox.

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2021 GonzoBanker Awards

Gonzobanker

This is an innovation-seeking franchise that has built a solid brand and never got over its skis in execution. Simultaneously the bank invested in Paladin Fraud, Trabian Technology, and Chartwell Compliance to provide compliance and risk management solutions in the complex and connected web of fintech partnerships. You tell us.

Fintech 148