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Another Maryland threat to bank partner model lending

CFPB Monitor

A Maryland administrative action recently removed to the state’s federal district court illustrates how Maryland law continues to present challenges for the bank partner structure used by many lenders. The new Maryland matter demonstrates that participants in bank model programs continue to face state licensing threats.

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California Dept. of Business Oversight launches “true lender” investigation of auto title lender’s partnership with Utah bank

CFPB Monitor

Because CCBank is a state-chartered FDIC-insured bank located in Utah, Section 27(a) of the Federal Deposit Insurance Act authorizes CCBank to charge interest on its loans, including loans to California residents, at a rate allowed by Utah law regardless of any California law imposing a lower interest rate limit.

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Why Aspiration Says Big Banks’ “Bad Decisions” Were Its Gain

PYMNTS

Maryland Representative Elijah Cummings and California’s Representative Jimmy Gomez, in an open letter to BoA CEO Brian Moynihan, said that many low-income American families rely on the account. Customers can also keep a daily balance of $1,500 to avoid fees. Those who do not meet those criteria will pay a $12 monthly fee.

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OppFi files complaint to block “true lender” challenge by California Department of Financial Protection and Innovation

CFPB Monitor

Maryland, New York, North Carolina, Ohio, Pennsylvania, West Virginia, and Colorado. In 2019, California enacted AB 539 which, effective January 1, 2020, limited the interest rate that can be charged on loans of $2,500 to $10,000 by lenders licensed under the California Financing Law (CFL) to 36% plus the federal funds rate.

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Are the regulators getting you down?

Jeff For Banks

The FDIC has nearly quadrupled its enforcement actions (“EA”) over the past three years. bank regulation banking banks Bay National Bank credit unions enforcement action FDIC formal agreement Jeff Marsico Kafafian OCC subk Suffolk Bancorp Suffolk County National Bank' The stark increase in such orders has been alarming.

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More Gain, Less Pain

Independent Banker

These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. Ellen Ryan is a freelance writer in Maryland. Private industry and ICBA had no input when FFIEC developed the tool, says Lilly Thomas, ICBA vice president and senior regulatory counsel.

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More Gain, Less Pain

Independent Banker

These agencies had input: the Federal Reserve, the Office of the Comptroller of the Currency, FDIC and the National Credit Union Administration. Ellen Ryan is a freelance writer in Maryland. Private industry and ICBA had no input when FFIEC developed the tool, says Lilly Thomas, ICBA vice president and senior regulatory counsel.

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