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South Dakota Payday Loan

Hundreds touch upon OCC proposed “true lender” guideline

Hundreds touch upon OCC proposed “true lender” guideline

These feedback reflected common themes, including assertions that: (1) the OCC does not have authority to adopt the Proposed Rule; (2) the Proposed Rule would deprive states of authority to manage non-bank loan providers; (3) the Proposed Rule would rise above the preemption authority issued by the NBA; (4) the Proposed Rule is “arbitrary and capricious”; (5) the Proposed Rule’s use procedure violates the APA; (6) the Proposed Rule would support lending that is predatory “rent-a-bank” schemes and as a consequence will be bad for customers and small enterprises; and (7) the Proposed Rule may have an anti-competitive influence on other state-licensed non-bank lenders. Many opinions advocated for jobs beyond the range associated with Proposed Rule, proposing that the OCC follow nationwide customer financing rate caps at 21per cent or 36%, or asking the OCC to previously reconsider the adopted Madden-fix rule.