California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank
CFPB Monitor
SEPTEMBER 10, 2020
In the past, “true lender” attacks have been launched or threatened by state authorities against high-rate bank/nonbank lending programs in DC, Maryland, New York, North Carolina, Ohio, Pennsylvania and West Virginia. Thus, both the OCC and FDIC have adopted regulations rejecting the Second Circuit’s Madden decision.
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