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Agency Proposals Reject Madden Holding: Six Things to Know
November 20, 2019, Covington Alert
On November 18 and 19, 2019, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) provided long-awaited regulatory affirmation that a bank loan’s rate of interest retains its non-usurious character when acquired by a third-party. The agencies each issued proposed rules that seek, as the OCC put it, to “codify what the OCC and the banking industry have always believed and address recent confusion about the impact of an assignment on permissible interest.”
July 21, 2020, Covington Alert
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) released a proposed rule intended to establish a bright-line test to identify the “true lender” in lending partnerships between national banks and federal savings associations, and third parties. Uncertainty in this area has caused confusion because the identity of the lender determines which ...
June 22, 2020, Covington Alert
In response to the COVID-19 pandemic, state and local lawmakers have implemented measures requiring financial institutions to provide relief to consumers, such as forbearance on loan payments or waiving fees. The OCC has released a bulletin reminding stakeholders that federally-chartered institutions generally are governed primarily by uniform federal standards ...
February 4, 2020, Covington Alert
On January 30, 2020, five federal financial regulators jointly issued a proposed rule that would modify existing regulations implementing the Volcker Rule’s general prohibition on banking entities investing in, sponsoring, or having certain relationships with hedge funds or private equity funds (collectively, “covered funds”). The proposal, which follows a 2019 ...