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OCC Finalizes True Lender Rule, Attempting to End Uncertainty around Bank-Fintech Partnership Models

The Office of the Comptroller of the Currency (OCC) issued a final rule that creates a bright-line test to determine when a national bank or federal savings association (bank) makes a loan and is the "true lender," including...more

Federal Reserve Finalizes Rule Updating Controlling Influence Framework

On January 30, the Federal Reserve released a highly anticipated final rule that substantially updates and clarifies the agency's regulatory framework for determining when an investor exercises a controlling influence over a...more

Financial Regulatory Observer - December 2019: Tailored enhanced prudential standards for non-US banks

Since the 2008 financial crisis, a non-US bank seeking to establish or maintain a US presence has been required to comply with a set of stringent regulatory requirements, but a recently adopted rule (Final Rule) limits their...more

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