Consumer Reports letter urging the Office of the Comptroller of the Currency to rescind its proposal that would give cover to lenders seeking to evade state usury laws by partnering with national banks to originate loans — commonly called the “rent-a-bank” model. The rent-a-bank model is not a new idea; in fact, it was used by payday lenders in prior decades to engage in risky lending activities. The OCC previously concluded that the model was unsafe and urged member banks to reconsider such partnerships. CR’s letter calls on the OCC urging it to remember the lessons of the past, respect states’ longstanding role in regulating interest rates on consumer loans, and rescind this proposal.