Who is the “True Lender”?
OCC seeks to nail down the definition of "true lender." Apparently it needed nailing down in this era of marketplace lenders. Here it is. Ready? A bank is the "true lender" if, as of the date of origination, the bank is named as the lender in the loan agreement or funds the loan. State regulators are not happy with the Federal angle on a matter that it believes should be a state matter. [7/22/20]