A&B ABstract: On October 27, 2020, the Office of the Comptroller of the Currency (“OCC”) issued a noteworthy final rulemaking that sets forth when a national bank or federal savings association originates a loan and is deemed...more
The Office of the Comptroller of the Currency (“OCC”) issued its long-anticipated final rule on Oct. 27, to establish a “simple, bright-line test” to determine when a national bank or federal savings association has made a...more
The Board of Governors of the Federal Reserve System (the Fed) recently released terms for its Main Street Lending Program (MSLP), a program authorized under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)...more