News & Analysis as of

Notice of Proposed Rulemaking (NOPR) Non-Bank Lenders

Seward & Kissel LLP

Proposed FDIC Rule Would Impose Additional Deposit Insurance Disclosure Obligations on Banks and Non-Banks

Seward & Kissel LLP on

The Federal Deposit Insurance Corporation (“FDIC”) published for comment in December 2022 a notice of proposed rulemaking (12 CFR Part 328) (“Proposed Rule”) that would apply to all FDIC-insured institutions and impose new...more

Foley & Lardner LLP

CFPB's Notice of Proposed Rulemaking

Foley & Lardner LLP on

On January 11, 2023, the Consumer Financial Protection Bureau (CFPB) issued a Proposed Rule that will, if adopted, require certain nonbank covered entities—including consumer reporting agencies (CRAs)—to register certain...more

Bradley Arant Boult Cummings LLP

OCC Proposes Clarification to True Lender Doctrine

Earlier this week, the OCC released a proposed rule designed to address the “true lender” doctrine, a legal test utilized by courts and regulators to determine whether a bank or its non-bank partner is the actual lender in a...more

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