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MoFo Reenforcement The Enforcement Blog

Not So Fast—State Attorneys General Seek to Enjoin OCC’s Final Rule Reaffirming “Valid When Made” Doctrine

Posted in Regulatory Developments

On July 29, 2020, the state attorneys general of California, Illinois, and New York filed suit against the Office of the Comptroller of the Currency (OCC) challenging the OCC’s Final Rule reaffirming the “valid when made” doctrine for loans originated by national banks.  The challenge extends the uncertainty created by the Second Circuit’s Madden decision until the litigation is resolved.

Read our client alert.