On August 27, 2021, the Board of Governors of the Federal Reserve, the Federal Deposit Insurance Corporation and the Office of the Comptroller of the Currency issued new guidance to community banks for conducting due...more
As most financial institutions and lenders are aware, in October 2020 the Office of the Comptroller of the Currency (the OCC) issued a rule that required the identification of the "true lender" of a loan to a customer if the...more
Earlier in March, the Federal Reserve Board (FRB), Federal Deposit Insurance Corporation (FDIC), National Credit Union Administration (NCUA) and Office of the Comptroller of the Currency (OCC and collectively with the FRB,...more