On Tuesday, February 8, 2022, the United States District Court for the Northern District of California issued two separate orders that upheld the OCC’s and FDIC’s “valid-when-made” rules.
In 2020, the OCC and FDIC issued...more
In recent months, we’ve provided several updates on “True Lender” and “Valid When Made” developments from the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and state...more
At long last, the FDIC has issued its final rule codifying the “valid when made” doctrine. The rule was finalized on June 25, 2020, and clarifies that the interest rate lawfully assessed by an originating depository...more
6/26/2020
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Valid When Made Doctrine