Bank Policy Institute filed 1 comment on this docket between Jan 22, 2020 and Jan 22, 2020. 19 other organizations filed here. The comment window closed 2380d ago.
The Structured Finance Association and Bank Policy Institute appreciate the opportunity to provide our response to the Comptroller of the Currency regarding the Proposed Rule: Permissible Interest on Loans that are Sold, Assigned, or Otherwise Transferred. Attached please find our joint comment letter. Regards, Jennifer Wolfe Director Structured Finance Association
Federal law establishes that national banks and savings associations (banks) may charge interest on loans at the maximum rate permitted to any state-chartered or licensed lending institution in the state where the bank is located. In addition, banks are generally authorized to sell, assign, or otherwise transfer (transfer) loans and to enter into and assign loan contracts. Despite these authorities, recent developments have created legal uncertainty about the ongoing permissibility of the interest term after a bank transfers a loan. This rule clarifies that when a bank transfers a loan, the interest permissible before the transfer continues to be permissible after the transfer.
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