Summary of the OCC True Lender Final Rule
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:
- Is named as the lender in the loan, or
- Funds the loan.
- 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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