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OCC Finalizes its “True Lender” Test: Paving the Way for Bank & Non-Bank Partnerships

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

Financial Regulators Issue Principles for Financial Institutions Offering Responsible Small-Dollar Loans

The federal banking agencies recently issued principles to encourage financial institutions to offer small-dollar loans in a responsible manner (the “Small-Dollar Loan Principles”). This interagency guidance clarifies...more

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