TAKEAWAYS The Senate has voted to repeal the True Lender Rule using the Congressional Review Act, a measure allowing Congress to disapprove of agency actions and nullify recently adopted administrative rules. The True Lender Rule is a recent Office of the Comptroller of the Currency rule designed to identify which party in a partnership between a national bank and a third party is deemed the “true lender.” Without the rule, these partnerships now face regulatory uncertainty, with legal and compliance requirements potentially determined on a case-by-case basis. On May 11, 2021, the Senate voted to repeal a Trump Administration regulation…
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