- Posts by Sanjay Ibrahim
PartnerAs the Managing Partner of Parker Ibrahim & Berg LLP, Jay Ibrahim is responsible for the strategic direction and growth of the firm since its founding in 2011. Under his leadership as chair of the Executive Committee, PIB Law has ...
Date: October 31, 2020
On October 27, 2020, the Office of the Comptroller of the Currency (OCC) issued its final “True Lender Rule.” As described in our original article found here the rule is intended to address when a national bank or federal savings association (each a “bank”) should be deemed a “true lender” of a loan.
Written July 24, 2020, updated September 20, 2020
On July 20, 2020, the Office of the Comptroller of the Currency (OCC) issued a proposed rule that would address when a national bank or federal savings association (each a “bank”) should be deemed a “true lender” of a loan. Under the proposed rule, a bank makes a loan if, as of the date of origination, it is named as the lender in the loan agreement or funds the loan. Regardless of its final form, if passed the rule will have material effects on banks and those third parties that partner with banks.
RSS Feed