On October 27, the Office of the Comptroller of the Currency (OCC) submitted a final rule for publication to determine when a national bank or federal savings association makes a loan to a third party and is the “true lender.” The rule clarifies that a bank is a “true lender” if, as of the date of origination, the bank (1) is named as the lender in the loan agreement or (2) funds the loan. OCC Bulletin.