News & Analysis as of

Office of the Comptroller of the Currency Loan Agreements

Sheppard Mullin Richter & Hampton LLP

House Votes to Repeal OCC True Lender Rule

On June 24, the U.S. House of Representatives passed S.J. Res. 15 by a vote of 218-208 to repeal the Office of the Comptroller of the Currency’s (OCC) “True Lender” rule under the Congressional Review Act (CRA). The OCC...more

Bradley Arant Boult Cummings LLP

OCC Releases Final True Lender Rule

On October 27, 2020, the OCC released its final True Lender Rule. As discussed earlier on this blog, the OCC’s rule is designed to clarify the “true lender” doctrine, a legal test utilized by courts and regulators to...more

Goodwin

Financial Services Weekly Roundup: The OCC’s True Lender Test Embraces A Simplified Solution

Goodwin on

In This Issue. The Office of the Comptroller of the Currency (OCC) proposed a rule that would establish that a national bank or federal savings association is the “true lender” of a loan if, as of the date of origination, the...more

Morrison & Foerster LLP

Will The True Lender Please Stand? – OCC Proposes “True Lender” Bright-Line Rule

On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a notice of proposed rulemaking that would establish when national banks or federal savings associations (collectively, banks) are the “true lender”...more

Orrick, Herrington & Sutcliffe LLP

Orrick's Financial Industry Week in Review

The Federal Housing Administration Announces New Loan Limits for 2016 - On December 9, 2015, the Federal Housing Administration ("FHA") announced its schedule of loan limits for the 2016 calendar year. The new schedule,...more

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