See a number of our work below.

Reinvestment Partners submitted these responses towards the workplace associated with the Comptroller associated with the Currency together with Federal Deposit Insurance Corporation in response for their joint approval allowing their user banking institutions to utilize their charters to evade state anti-usury regulations. The proposition, if authorized, allows banking institutions to disregard state rules that put ceilings on interest levels. New york features a strong state guideline that caps rates of interest at 30 %. Underneath the «Rent-a-Bank» model, since it is described, banking institutions could mate with payday loan providers to supply loans with rates of interest in excess of 200 %.

Reinvestment Partners submitted this comment to your workplace of this Comptroller for the Currency regarding the agency’s proposal to generate a special-purpose nationwide charter for fintech businesses. More