On Wednesday, February 5, the House Financial Services Committee will hold the first part of a two-part hearing on “rent-a-bank” structures. The hearing is titled “Rent-A-Bank Schemes and New Debt Traps: Assessing Efforts to Evade State Consumer Protections and Interest Rate Caps.” (Part Two is scheduled for February 26.)
The Committee Memorandum for Part One discusses the relevant case law, including Marquette and Madden, and the OCC’s and FDIC’s proposals to undo Madden. … Continue Reading