The OCC issued guidance on the applicability of the legal lending limit to purchased loans.
Details: The bulletin says:
Unless an exception applies, all loans and extensions of credit made by banks are subject to the LLL, which provides limitations on the total amount of loans and extensions of credit to any one borrower.
Aggregate exposures attributable to a single seller must be within the bank’s LLL.
Loans are attributable to a seller under federal regulations if the bank has direct or indirect recourse to the seller.
If the bank does not have explicit or implied recourse to the seller, the loans are generally not attributable to the seller.
