The OCC’s Final Rule to Undo Madden: An Analysis and A Look Ahead
The OCC marked the departure of Comptroller of the Currency Otting by issuing a final rule intended to resolve the legal uncertainty created by the Second Circuit’s decision in Madden v. Midland Funding. The Second Circuit held that a nonbank that purchased charged-off loans from a national bank could not charge the same rate of interest on the loan that Section 85 of the National Bank Act allowed the national bank to charge.
In this webinar we will analyze and discuss the final rule’s implications for industry and the challenges the rule could face. Topics will include: