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Valid When Made Doctrine Rulemaking Process

Goodwin

SEC Proposes Changes to Private Fund Regulation

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In This Issue. The U.S. Securities and Exchange Commission (SEC) proposed changes to private fund regulation; the Office of the Comptroller of the Currency (OCC) succeeded in validating its “valid-when-made” rulemaking; the...more

Sheppard Mullin Richter & Hampton LLP

OCC Prevails in Challenge to “Valid When Made” Rule

On February 8, the U.S. District Court for the Northern District of California ruled against three states – California, Illinois, and New York – challenging the OCC’s rule on the “valid when made” doctrine. In 2020, the OCC...more

Ballard Spahr LLP

Hundreds comment on OCC proposed “true lender” rule

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We recently published a blog about the OCC’s proposed rule “National Banks and Federal Savings Associations as Lenders” (the “Proposed Rule”), which would clarify that a bank (or savings association) is properly regarded as...more

Goodwin

Bank Regulators Propose Fix to Madden Problem

Goodwin on

Last week, the Office of the Comptroller of the Currency (OCC) and Federal Deposit Insurance Corporation (FDIC) each issued a proposed rule designed to clarify that interest rates that are valid when a loan is made remain...more

Ballard Spahr LLP

Republican lawmakers urge OCC to address Madden through rulemaking

Ballard Spahr LLP on

The Republican members of the House Financial Services Committee have sent a letter to Comptroller of the Currency Joseph Otting urging the OCC to make action to address the uncertainty created by Second Circuit’s Madden...more

Ballard Spahr LLP

House Financial Services Committee passes Financial Choice Act containing CFPB overhaul, significant changes to rulemaking...

Ballard Spahr LLP on

Last Thursday, by a party-line vote of 34-26, the House Financial Services Committee approved the Financial CHOICE Act (H.R. 10) proposed by Committee Chairman Jeb Hensarling....more

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