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Student Loan Borrowers Beware: You May Owe State Tax on the Forgiven Debt Even If You Do Not Receive an IRS Form 1099-C

As reported late last year, the IRS announced in Notice 2022-1 (Notice) that lenders are not required to, and should not, issue IRS Forms 1099-C when certain student loan debts are forgiven. The Notice was in response to...more

CFPB Takes Adverse Action Against Machine Learning

The Consumer Financial Protection Bureau (CFPB) has been contemplating data, algorithms, and machine learning for years. In 2017, as part of a field hearing on alternative data, the CFPB issued a request for information in...more

Federal Court Upholds OCC and FDIC Valid When Made Rules

On Tuesday, February 8, 2022, the United States District Court for the Northern District of California issued two separate orders that upheld the OCC’s and FDIC’s “valid-when-made” rules. In 2020, the OCC and FDIC issued...more

OCC Issues Final Rule On True Lender

The Office of the Comptroller of the Currency (OCC) issued a final rule last week to establish a “simple, bright-line test” to determine when a national bank or federal savings association is the true lender. Under the rule,...more

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