News & Analysis as of

Banks Interest Rates Office of the Comptroller of the Currency

Orrick, Herrington & Sutcliffe LLP

OCC releases semiannual Interest Rate Risk Statistics Report

Recently, the OCC released its Spring 2025 Interest Rate Risk Statistics Report detailing interest rate risk data gathered during examinations of OCC-supervised midsize and community banks and federal savings associations....more

Orrick, Herrington & Sutcliffe LLP

OCC releases March 2025 enforcement actions

On March 20, the OCC released a list of recent enforcement actions taken against national banks, federal savings associations, and individuals affiliated with supervised banks. Among the actions taken, the OCC issued a cease...more

Orrick, Herrington & Sutcliffe LLP

OCC releases its Interest Rate Statistics Report from 2022 to 2024

On October 21, the OCC released its semiannual Interest Rate Risk Statistics Report, which presented data the OCC collected during examinations of midsize and community banks and federal savings associations. The report...more

Ballard Spahr LLP

Important National Bank Act (NBA) preemption case to be argued Today, February 27, before US Supreme Court

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The oral argument in Cantero v. Bank of America, N.A. will be heard on Tuesday, February 27 before the US Supreme Court. The Court recently granted the unopposed motion of the Solicitor General to participate in the oral...more

Moore & Van Allen PLLC

Preemption Update and Future Implications: Congress Repeals The OCC’s True Lender Rule

Moore & Van Allen PLLC on

Congress has voted to overturn the Office of the Comptroller of the Currency’s (“OCC’s”) “true lender” rule under the Congressional Review Act (“CRA”), and the President has signed the resolution. Repeal of the “true lender”...more

Goodwin

CFPB Grants No-Action Letter for Proposed Small-Dollar Credit Product

Goodwin on

In the News. The Consumer Financial Protection Bureau (CFPB) granted a no-action letter (NAL) regarding a proposed small-dollar credit product and sought comment on the CFPB’s plan to study how consumers locate, comprehend...more

Morgan Lewis - All Things FinReg

OCC Issues Final ‘True Lender’ Rule

The Office of the Comptroller of the Currency (OCC) issued a final rule on October 27 that determines when a national bank or federal savings association (bank) makes a loan and is the “true lender” in the context of a...more

Bradley Arant Boult Cummings LLP

OCC Proposes Clarification to True Lender Doctrine

Earlier this week, the OCC released a proposed rule designed to address the “true lender” doctrine, a legal test utilized by courts and regulators to determine whether a bank or its non-bank partner is the actual lender in a...more

Ballard Spahr LLP

FDIC Issues “Madden fix” Rule Addressing State Bank Loan Interest Rates After Assignment

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The FDIC has issued its widely anticipated final rule resolving the uncertainty caused by the Second Circuit’s Madden v. Midland Funding decision. Madden held that a non-bank entity that purchased charged-off loans from a...more

Clark Hill PLC

OCC Issues Final “Valid-When-Made” Rule: Does it End the Madness of Madden v. Midland Funding?

Clark Hill PLC on

Last Friday, the Office of the Comptroller of the Currency (“OCC”) issued a final rule providing that interest rates established on debt originated by a national bank remain valid even after the debt is transferred to a...more

Ballard Spahr LLP

House Financial Services Committee announces January hearings on CRA, “rent-a-bank schemes,” mobile payments

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The House Financial Services Committee has announced that it will hold the following hearings this month: On January 14, the Subcommittee on Consumer Protection and Financial Institutions will hold a hearing entitled, “The...more

Morrison & Foerster LLP

After Madden, OCC and FDIC Propose to Reaffirm “Valid When Made” Rule

Morrison & Foerster LLP on

On November 18, 2019, the Office of the Comptroller of the Currency (OCC) took action to reaffirm the “valid when made” doctrine in response to the uncertainty on the validity of interest rates of bank-originated loans sold...more

Troutman Pepper Locke

FDIC And OCC Issue Strong Rebuke To Madden In Joint Amicus Brief: 'madden Is Not Just Wrong; It Is Unfathomable'

Troutman Pepper Locke on

On September 10, the FDIC and the OCC jointly submitted an amicus brief to the U.S. District Court for the District of Colorado in support of the appellee debt buyer in In re Rent-Rite Super Kegs West Ltd. ...more

Goodwin

Financial Services Weekly News - May 2017 #4

Goodwin on

Editor's Note - Memorial Day. On Memorial Day, we will be celebrating the men and women whose service and sacrifice ensures the preservation of freedom and opportunity across the United States. Rather than summarize the...more

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