As promised by Acting Comptroller Brooks, the OCC has quickly followed up its controversial valid-when-made rule with a proposal defining “true lender” to facilitate the partnerships between banking organizations and other financial companies sometimes called “rent-a-bank” charters.  Perhaps due to FDIC Chair McWilliams’ concerns about the use of banks to “evade” state restrictions, the FDIC has finalized a comparable valid-when-made rule for state-chartered banks, but has yet to follow the OCC’s lead with its own true-lender proposal.

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