Digital Library: New Angles in Challenging Rent-a-Bank Schemes
Predatory lenders use rent-a-bank schemes to avoid the usury limits of the consumer’s state, by seeking to bootstrap onto federal rate exportation rights available only to banks. These predatory non-bank lenders claim that they are only arrangers or servicers of credit originated by a bank. NCLC’s Consumer Credit Regulation § 3.5.4 sets out several challenges to such arrangements—such as…
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