Unfortuitously, your proposed guideline is just a style of loan laundering that will allow non-bank loan providers to circumvent our state legislation and work out customer loans that exceed our limits that are state’s.

Unfortuitously, your proposed guideline is just a style of loan laundering that will allow non-bank loan providers to circumvent our state legislation and work out customer loans that exceed our limits that are state’s.

Here’s just exactly how this proposition undermines Colorado legislation. A non-bank lender, which may ordinarily have to follow Colorado’s restrictions should they were making the mortgage, could be permitted to determine Colorado clients and obtain loan applications completed and then deliver the applications up to a nationwide bank. That bank would then be permitted to deliver the buyer the income when it comes to loan but quickly sell the mortgage back into the lender that is non-bank a charge additionally the non-bank lender would then administer the mortgage and gather the fees and interest. The non-bank lender would not have to follow our state rate cap rules and could charge APR’s of 100% or more by“renting the bank” in this way.

This will be a “rent-a-bank” proposal – the non-bank loan provider is essentially spending the out-of-state bank to hire its charter. The lending company makes use of this arrangement to purchase the capability to disregard the rate of interest caps regarding the states like Colorado in which they wish to run. Read More “Unfortuitously, your proposed guideline is just a style of loan laundering that will allow non-bank loan providers to circumvent our state legislation and work out customer loans that exceed our limits that are state’s.”

Go Top