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Food for Thought: A Policy on Credit Exceptions

Abrigo

unsecured lending is bad rather than unsecured lending should only be extended to high pass risk rated credit). As the FDIC said recently: Exceptions to policy should be few in number and properly justified, approved, and tracked. Get details in "A guide to implementing credit policy."

Policies 195
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OCC issues proposed “true lender” rule

CFPB Monitor

24, 1464(c), and 371, respectively) that allow national banks and federal savings associations to extend credit do not indicate how to determine when a bank has exercised such authority and, rather than its relationship partner, has made a loan. Presumably, we will soon see a proposed “true lender” rule from the FDIC.

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Consumer Lending Compliance: Hot-Button Issues to Monitor

Abrigo

Consumer Lending Laws & Compliance Financial institutions offering consumer loans need to know about these major consumer lending laws and recent compliance issues. You might also like this webinar, "Consumer Lending 101.". Consumer lending compliance spotlight. Pandemic Issues.

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NY federal district court deals blow to OCC fintech charter

CFPB Monitor

. § 520(e)(1), which contains a sentence that directly justifies the SPNB charter: “A special purpose bank that conducts activities other than fiduciary activities must conduct at least one of the following three core banking functions: Receiving deposits; paying checks; or lending money.” Supreme Court’s 1984 decision Chevron U.S.A.

Fintech 68
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DoD issues MLA interpretive rule; Ballard to hold Sept. 20 webinar

CFPB Monitor

The Department of Defense (DoD) has issued an interpretive rule to assist the industry in complying with its July 2015 final rule amending the Military Lending Act’s implementing regulation. are expressly intended to finance the purchase of the personal property and are secured by the personal property being purchased).”