To our clients and friends:
The Office of the Comptroller of the Currency (“OCC”) recently issued a final rule clarifying that when a national bank or federal savings association transfers a loan, the interest rate permissible before the transfer continues to be permissible after transfer. The final rule applies to national banks and federal savings associations and is effective on August 3, 2020. The Federal Deposit Insurance Corporation previously issued a substantively similar proposed rule as to state banks and is likely to follow the OCC in issuing the rule in final.
Our Alert is available here.