Closer Look: OCC Final Rule Reacts To The Problematic Madden Decision On Interest Rate Transfers

LexisNexis (July 21, 2020, 8:33 AM EDT) -- As his first major policy initiative, on the day he assumed office, acting Comptroller of the Currency Brian Brooks spearheaded the release of the OCC’s final rulemaking on permissible interest rate transfers. The Final Rule is intended to offer comfort to national banks and federal savings associations relying on the “valid-when-made” common law principle, which protects the interest rate on a loan after the loan is transferred....