Walter E. Zalenski discussed "Is valid when made ... valid?" at the Women in Housing & Finance Partner Series webinar
OCC Acting Comptroller has hit the ground running, issuing a number of regulatory announcements during his first weeks as Comptroller. Among those are the complementary announcements regarding the adoption of the final Madden Rule and the proposal to determine when a national bank or FSB is the “true lender” of an extension of credit made in the context of a partnership between a bank and a third party.
On July 29, the state attorneys general of California, Illinois, and New York filed suit against the OCC challenging the Madden final rule. Buckley law firm attorneyWalter Zalenski discussed the recent OCC rulemakings and the AG filing and the future of whether valid when made is … valid.