Ballard Spahr Submits Comment Letter to OCC in Support of Proposed True Lender Rule
CFPB Monitor
SEPTEMBER 9, 2020
1831d(a) (“Section 27(a)”), which governs the interest charges of state-chartered FDIC-insured banks. 93a, the OCC is generally “authorized to prescribe rules and regulations to carry out the responsibilities of the office.” Citibank (South Dakota), N.A., The OCC clearly has the authority to adopt the Proposed Rule.
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