FDIC and OCC try to Settle Uncertainty produced by Second Circuit’s Madden choice

FDIC and OCC try to Settle Uncertainty produced by Second Circuit’s Madden choice “True lender” uncertainty remains The agencies explicitly do not address the validity of certain bank-fintech partnership models that remain subject to “true lender” challenges and regulatory scrutiny while the proposed rules seek to remediate the legal uncertainty resulting from the Madden decision. […]

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