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Office of the Comptroller of the Currency Assignments

Ballard Spahr LLP

FDIC Issues “Madden fix” Rule Addressing State Bank Loan Interest Rates After Assignment

Ballard Spahr LLP on

The FDIC has issued its widely anticipated final rule resolving the uncertainty caused by the Second Circuit’s Madden v. Midland Funding decision. Madden held that a non-bank entity that purchased charged-off loans from a...more

Dechert LLP

Federal Regulators to the Rescue? The OCC and FDIC Propose Rules to Address Madden Risk.

Dechert LLP on

With the hope of finally addressing the uncertainty created by the U.S. Second Circuit Court of Appeal’s holding in Madden v. Midland Funding,1 the Office of the Comptroller of the Currency (OCC) and the Federal Deposit...more

BCLP

OCC and FDIC Clarify the “Valid When Made” Debate

BCLP on

On November 18 and 19 of this week, the Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued Advanced Notices of Proposed Rulemaking (ANPRs) to clarify how state interest rate caps...more

Buchalter

OCC Issues Proposed Rule to Clarify “Valid-When-Made” Doctrine; Would Affirm That an Interest Rate that Is Permissible at the Time...

Buchalter on

The Office of the Comptroller of the Currency and the Federal Deposit Insurance Corporation issued a Notice of Proposed Rulemaking (Notice) that would affirm that when a national bank or savings association sells, assigns, or...more

BCLP

Reviewing Third Party Vendor Service Contracts, a Seven Part Guide

BCLP on

Managing third party vendor relationships has always been an important function in banks. More recently it has become a hot topic for state and federal financial bank regulators. The increasing complexity of what vendors are...more

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