A&B Abstract: As we have previously reported, effective August 3 the Office of the Comptroller of the Currency’s (“OCC”) has issued a final rule affirming the “valid-when-made” doctrine while dismissing the Second Circuit decision in Madden v. Midland Finding, LLC. On June 9, 2020, however, a Colorado state court handed down an unexpectedly negative ruling […]
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OCC Rule Affirms Valid-When-Made Doctrine
A&B ABstract: On May 15, the Office of the Comptroller of the Currency (“OCC”) issued a final rule, effective August 3, 2020, addressing the “valid-when-made” doctrine. The rule clarifies that the interest rate on a loan originated by a national bank or federal savings association, if permissible at the time of origination, will continue to be […]