Summary of the OCC True Lender Final Rule

Updated 11/06/2020

The Office of the Comptroller of the Currency (OCC) issued this final rule to clarify when a national bank or Federal savings association makes a loan and is the “true lender” in the context of a partnership between a bank and a third party. The rule 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, or
  2. Funds the loan.
  3. When there are two banks where one bank is named as the lender in the loan agreement for a loan and another bank funds that loan, the bank that is named as the lender in the loan agreement makes the loan.

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