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After reviewing the legal foundation for federal preemption of state law limits on interest, we discuss the OCC's proposed approach for determining when a bank is the "true lender" in programs with non-bank agents, ...
within Insolvency/Bankruptcy/Re-Structuring, Law Department Performance and International Law topic(s)
After reviewing the legal foundation for federal preemption of
state law limits on interest, we discuss the OCC's proposed
approach for determining when a bank is the "true lender"
in programs with non-bank agents, our arguments in support of the
proposal made in our comment letter to the OCC, key arguments made
in support of or against the proposal by other commenters, the
OCC's likely next steps, and the 2020 election's potential
impact.
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