Dear Representative Hollingsworth:
with respect to the Conference of State Bank Supervisors (CSBS), 1 I am composing to state our members’ severe concerns with and opposition towards the Modernizing Credit Opportunities Act (H.R. 4439), which seeks to determine that the bank could be the “true lender” in every loan project arrangement with a third-party company. State regulators payday loans Idaho have window that is unique bank and non-bank financing relationships by virtue of these work chartering banking institutions, licensing non- bank loan providers, and overseeing the conduct of both forms of entities, including lending partnerships amongst the two. State regulators will also be the “boots on the floor,” policing their areas to guard consumers from harmful and exploitative financial loans that run afoul of state rules.
State regulators are worried that H.R. 4439 could cause “rent-a-charter” arrangements between banking institutions and non-bank loan providers that have already been specifically made to circumvent state usury and licensing rules. Continue reading “Real loan that is payday. State usury legislation and non-bank certification requirements are really a component that is critical of security.”