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Does the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) waive bank legal lending limits?
No. The CARES Act temporarily permits the Comptroller of the Currency to, by order, exempt any transaction or series of transactions from the requirements of the national bank legal lending limits upon a finding by the Comptroller that such exemption is in the public interest and consistent with the purposes of the limits. The Michigan Banking Code of 1999 authorizes the DIFS Director to make exceptions to state bank legal lending limits via order or declaratory ruling.