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Rocky Mountain Low? Implications of the Settlement of Colorado's Challenge to Partnerships Between Banks and Marketplace Lenders

The impact of state usury laws on marketplace lending has been an area of concern since the inception of the industry. In a technique borrowed from the payday lending industry, online platforms that make unsecured consumer...more

COVID-19: Federal Reserve’s Commercial Paper Funding Facility 2020 May Enhance Consumer Lending and Corporate Liquidity

“Wishing you a pot o’ gold, and all the joy your heart can hold.” – traditional St. Patrick’s Day greeting - On March 17, 2020, the Federal Reserve Board announced the establishment of the Commercial Paper Funding Facility...more

OCC and FDIC Propose Rules to Confirm “Valid-When-Made” Doctrine

Over the last two days, the Office of the Comptroller of the Currency (“OCC”) and the Federal Deposit Insurance Corporation (“FDIC”) (together, the “Agencies”) each issued a proposed rule (collectively, the “Proposed Rules”)...more

11/25/2019  /  FDIC , Lenders , OCC , Proposed Rules

Costly Thy Habit As Thy Purse Can Buy: Implications of the Proposed HVADC Rules for Borrowers and Lenders of Acquisition,...

On September 27, 2017, the Office of Comptroller of the Currency, the Board of Governors of the Federal Reserve System, and the Federal Deposit Insurance Corporation (the “Agencies”) released a joint Notice of Proposed...more

Commercial Mortgage Loans and CMBS: Developments in the European Market – Chapter 20

In late 2011 and early 2012, the fragile green shoots of recovery began to peek out from the barren blasted heath of the crisis-blown financial markets. Market activity was spurred by a rare confluence of secular trends,...more

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