News & Analysis as of

Consumer Financial Protection Bureau (CFPB) Promissory Notes

Spilman Thomas & Battle, PLLC

Promissory Notes - Banking & Finance Insights: V 4, Issue 2, March 2024

Volume 4, Issue 2, 2024 Welcome! Welcome to the second issue of Promissory Notes - our banking and finance e-newsletter - for 2024. Business today is characterized by relentless change. To assist our clients in navigating...more

Orrick, Herrington & Sutcliffe LLP

OCC and FDIC Successfully Defend Valid-When-Made Rules

The Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) have successfully defended their respective valid-when-made rules. On February 8, 2022, Judge Jeffry S. White, U.S....more

Ballard Spahr LLP

Federal court rejects Madden and finds loan valid when made per OCC final rule, but remands case to allow discovery on true lender...

Ballard Spahr LLP on

In an order issued August 12, 2020, the United States District Court for the District of Colorado relied on the OCC’s “Madden fix” rule to hold that, under Section 27 of the Federal Deposit Insurance Act, 12 U.S.C. § 1831d, a...more

Orrick - Finance 20/20

Regulators Release Guidance on Private Student Loans With Graduated Repayment Terms at Origination

On January 29, the federal financial regulatory agencies (the Board of Governors of the Federal Reserve System, the Consumer Financial Protection Bureau, the Federal Deposit Insurance Corporation, the National Credit Union...more

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