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CoalitionLow RiskMultistate

Attorney General Jennifer Davenport Opposes Predatory Lender OppFi’s Bid for National Bank Charter

Opportunity Financials, LLCAugust 6, 2026New Jersey Attorney General

Summary

Attorney General Jennifer Davenport joined a coalition of 17 attorneys general in sending comment letters to the Office of the Comptroller of the Currency and the Federal Reserve Board, urging them to deny OppFi's application to acquire BNC National Bank and obtain a national bank charter. The coalition argues that the charter would allow OppFi to circumvent state usury laws and offer high-cost loans with APRs up to 200%, harming consumers.

Contract Impact

In-house legal teams at financial services companies should review their lending agreements and bank partnership arrangements to ensure compliance with state usury laws and interest rate caps. Specifically, they should examine any 'rent-a-bank' structures that may be used to export interest rates from states without caps, and ensure that their contracts do not facilitate circumvention of state consumer protection laws. They should also review their loan agreements for APR disclosures and ensure they are not engaging in predatory lending practices that could attract regulatory scrutiny.

Contract Search Terms

rent-a-bankinterest rate capusury lawbank charterstate lending compliancehigh-cost loanAPR limitconsumer loan agreementTrue Lender RuleNational Bank Act

Laws Cited

New Jersey usury lawsNational Bank Act

Violation Types

Entity Details

Entity

Opportunity Financials, LLC

Industry

Financial Services

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"Opportunity Financials’ (OppFi)"
Laws Cited
"New Jersey’s usury laws"
Laws Cited
"National Bank Act"
Violation Types
"circumvent longstanding state lending laws"

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