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FDIC and OCC try to Settle Uncertainty produced by Second Circuit’s Madden choice

“True lender” uncertainty remains

The agencies explicitly do not address the validity of certain bank-fintech partnership models that remain subject to “true lender” challenges and regulatory scrutiny while the proposed rules seek to remediate the legal uncertainty resulting from the Madden decision. 3 The lender that is“true issue has arisen checkmate loans hours within the context of particular lending arrangements between a bank and a non-bank entity, which experts have actually referred to as “rent-a-charter” or “rent-a-bank” schemes. Continue reading

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