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Valid When Made Doctrine State Attorneys General

Morgan Lewis - All Things FinReg

“Madden Fix” Rules Withstand a Key Test: What Happens Next

More than six years after it was decided, the practical consequences of the US Court of Appeals for the Second Circuit’s Madden v. Midland Funding, LLC decision continue to diminish. The decision—which held that, under some...more

Goodwin

States Challenge FDIC “Valid When Made” Rule With New Lawsuit

Goodwin on

On August 20, 2020, seven states – California, Illinois, Massachusetts, Minnesota, New Jersey, New York, and North Carolina – and the District of Columbia (together, the States) filed suit against the Federal Deposit...more

Manatt, Phelps & Phillips, LLP

State Attorneys General Challenge OCC’s ‘Madden Fix’ Rule

As expected, the attorneys general of three large states have sued to block the “Madden fix” rule recently adopted by the Office of the Comptroller of the Currency (OCC). The lawsuit ensures that the uncertainty surrounding...more

Nutter McClennen & Fish LLP

Fintech in Brief: State Attorneys General File Lawsuit Challenging OCC’s ‘Valid When Made’ Rule

On July 29, 2020, the state attorneys general for California, Illinois, and New York filed a complaint against the Office of the Comptroller of the Currency (“OCC”) challenging the OCC’s final “valid when made” rule (the “OCC...more

BCLP

New York, California and Illinois Sue OCC to Block “Valid When Made” Rule

BCLP on

Just two months ago, the Office of Comptroller of the Currency (“OCC”) addressed the “valid when made” doctrine and held that interest rates established on bank-originated loans remain valid even after the loan is transferred...more

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