CSBS is requesting comment on a Model Money Services Businesses Law for states.

A new series of CSBS papers will describe the various business segments within the nonbank industry, explain how they are currently licensed and supervised by state financial regulators, and discuss issues affecting regulatory changes going forward

CSBS formally requests the FDIC and OCC to extend the deadline for comment period on the Notice of Proposed Rulemaking on Community Reinvestment Act Regulations.

While the agencies are seeking to provide greater certainty as to the ability of assignees to enforce interest rate provisions of loans originated by banks, CSBS believes, as bank partnerships with nonbanks continue to increase, the “true lender” doctrine needs to be preserved as an important tool for addressing rent-a-bank arrangements and preserving state consumer protections.