Alert August 12, 2008

OCC Issues Opinion on Op Sub Interest Exportation

The OCC published an interpretive letter opining that, based on the facts presented by the party requesting the opinion, an operating subsidiary of a national bank should export the interest rate and fees considered interest that the most-favored lender may charge in its parent bank’s home state, even though the operating subsidiary has no offices located in that home state. Click here for the letter.