Dear Representative Hollingsworth:
With respect to the Conference of State Bank Supervisors (CSBS), 1 i will be composing to state our membersвЂ&https://www.thetotalpackage.shop/x2122; severe concerns with and opposition to your Modernizing Credit Opportunities Act (H.R. 4439), which seeks to ascertain that a bank may be the “true lender” in almost any loan project arrangement by having a third-party company. State regulators have a window that is unique bank and non-bank financing relationships by virtue of the work chartering banking institutions, licensing non- bank loan providers, and overseeing the conduct of both kinds of entities, including financing partnerships involving the two. State regulators will also be the “boots on a lawn,” policing their areas to safeguard customers from harmful and exploitative financial loans that run afoul of state laws and regulations.
State regulators are involved that H.R. 4439 could cause “rent-a-charter” arrangements between banking institutions and lenders that are non-bank have already been specifically made to circumvent state usury and licensing laws and regulations.