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Congress Uses Congressional Review to Overturn OCC’s True Lender Rule

On June 24, the House of Representatives, like the Senate on May 11, voted to overturn the Office of the Comptroller of Currency’s (OCC) “True Lender Rule” that was finalized in October 2020. The Senate initiated the process...more

Securitization Trust Defeats Efforts to Apply Madden

In the first case decided on the issue of whether Madden v. Midland Funding, LLC is applicable to a credit card securitization, the United States District Court for the Western District of New York, on September 21, 2020,...more

OCC Issues Valid-When-Made Rule With an Eye Toward Legal Challenges

The OCC’s new rule titled “Permissible Interest on Loans That Are Sold, Assigned, or Otherwise Transferred” (the Permissible Interest Rule) states that a national bank “may transfer a loan without impacting the permissibility...more

FDIC And OCC Issue Strong Rebuke To Madden In Joint Amicus Brief: 'madden Is Not Just Wrong; It Is Unfathomable'

On September 10, the FDIC and the OCC jointly submitted an amicus brief to the U.S. District Court for the District of Colorado in support of the appellee debt buyer in In re Rent-Rite Super Kegs West Ltd. ...more

Conference of State Bank Commissioners Sues OCC to Bar Chartering of Fintech Banks

The CSBS’ request for an injunction may prompt the OCC to slow down or abandon its willingness to consider issuing national bank charters to fintech companies....more

Remand Decision in Madden v. Midland Funding Raises Questions Regarding Choice of Law Clauses in Consumer Loan Agreements

A careful parsing of state laws should be done if a lender is relying on a choice of law to avoid states that have criminal usury statutes. On February 27, the U.S. District Court for the Southern District of New York...more

New True Lender Case Provides Support for the Bank Partnership Model

The court explicitly acknowledged that making it difficult for banks to assign or sell their commercial property to the secondary market impedes good public policy. On September 20, the U.S. District Court for the...more

The Solicitor General Weighs in on Madden v. Midland

The Solicitor General’s brief argues the Second Circuit’s holding was incorrect, but does not recommend a grant of certiorari. On May 24, the U.S. Solicitor General and the Office of the Comptroller of the Currency...more

Update on Madden v. Midland: Cert. Decision Expected Soon

The certiorari petition asks the court to address whether the National Bank Act continues to have preemptive effect after the national bank has sold or otherwise assigned a loan to another entity. In a petition for a...more

Valid at Inception Rule Shot Down by the Second Circuit

Marketplace lenders and investors that purchase interests in loans originated by banks should pay close attention as it could spawn a host of class action lawsuits if left standing. In a controversial opinion decided on...more

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