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OCC’s Attempt at Clarifying “True Lender” Principle Met with Mixed Results

On July 22, 2020, the Office of the Comptroller of Currency (“OCC”) proposed a new rule in the federal register, concerning when a bank or savings association is a “true lender,” when the loan is sold or assigned to different...more

Square Obtains FDIC Charter To Operate Its Own Bank As An Industrial Loan Company

On March 18, 2020, Square Inc., became the first U.S. fintech company to receive conditional approval of an Industrial Loan Company (“ILC”) charter from the Federal Deposit Insurance Corporation (“FDIC”), to pair with its...more

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