On July 20, 2020, the OCC (Office of the Comptroller of the Currency) released a proposal to determine who is the "true lender" of loans, in the context of a partnership between a national bank and a third party, such as a payday lender.

The changes proposed were made under the guise of providing more people with access to credit. However, the proposed changes would actually remove consumer protections enacted by states. This rule allows payday, car title, and other high-interest installment lenders to operate in states where they are banned or where interest rates are normally capped. By partnering with banks in other states and listing that bank as the "true lender" of a loan, these predatory lenders can legally charge interest rates of over 400%!  

We’re trying to close this loophole and stop this "Rent-a-Bank" scheme to protect consumers.

Let your voice be heard! Submit a comment to the OCC and tell them to stop shielding predatory lenders and protect consumers from abuse.  

Read more about the proposed rule change from the OCC here: OCC Proposed Rule: True Lenders & Rent-a-Bank Schemes

Please note: By filling out this form, your name, address and comment will be submitted to the Federal Register and will be posted on the Regulations.gov website. The deadline to submit your comment is September 3, 2020. Make a difference and let your voice be heard.