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MoFo Reenforcement The Enforcement Blog

Stop in the Name of the True Lender: President Biden Repeals OCC True Lender Rule

Posted in Regulatory Developments

On June 30, 2021, President Biden signed a Congressional Review Act (CRA) resolution rescinding the OCC True Lender Rule, a bright-line rule issued in October 2020 to simplify the standards governing when a traditional bank in a partnership with a non-bank is the “true lender.” The rule provided that a bank is the true lender if, as of the date of origination, it (1) is named as the lender in the loan agreement or (2) funds the loan.

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