The Office of the Comptroller of the Currency (OCC) has issued its “true lender” rule introduced earlier this year with added clarification about how banks are responsible for the actions of their third-party lending partners.
The OCC’s rule, slated to take effect 60 days after publication in the Federal Register, “specifies that a bank makes a loan and is the true lender if, as of the date of origination, it (1) is named as the lender in the loan agreement or (2) funds the loan.” The rule is intended to bolster accountability for banks regarding their third-party partners, clarifying which lender in the arrangement is responsible for following all federal banking laws.
