FDIC issues “Madden fix” rule addressing state bank loan interest rates after assignment
CFPB Monitor
JUNE 29, 2020
The FDIC has issued its widely anticipated final rule resolving the uncertainty caused by the Second Circuit’s Madden v. The FDIC’s Notice of Proposed Rulemaking (“NPR”) was published the same week as an OCC proposed rule intended to address the same issue for national banks under Section 85. Midland Funding decision.
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