Another Maryland threat to bank partner model lending
CFPB Monitor
MAY 6, 2021
In addition, legal challenges to the OCC and FDIC “ Madden -fix” rules and the OCC’s “true lender” rule continue to create uncertainty for participants. As a result, participants would be well-advised to revisit their compliance with state licensing laws and their vulnerability to “true lender” and Madden challenges.
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