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FTC Follows up on Enforcement Priorities with Complaint Against Merchant Cash Advance Provider

USA - August 11 2020 Following a warning from earlier this year, the FTC recently filed a complaint against a group of corporate and individual defendants for allegedly…

Ellen Traupman Berge, Andrew E. Bigart, Leonard L. Gordon, Makalia A. Griffith

Fighting the Fix: Three States Sue the OCC for Codifying the Valid When Made Doctrine

USA - August 7 2020 In the midst of the economic fallout from a global pandemic, struggling consumer lenders saw a glimmer of good news when two federal banking…

R. Andrew Arculin, Allyson B. Baker

The Elusive Madden Fix Part 2: FDIC Codifies "Valid When Made" for Loans by State Banks

USA - August 4 2020 As we explained in Part 1, the Office of the Comptroller of the Currency (OCC) implemented a "Madden Fix" for national banks and federal savings…

Please Disrupt Me: Regulatory Concerns in Fixing Healthcare Payments

USA - July 9 2020 America's fragmented systems for billing and making healthcare payments are ripe for the sort of "disruption" that has revolutionized the delivery of…

Andrew E. Bigart, Thora A. Johnson, Celia E. Van Lenten

The Elusive Madden Fix: OCC Codifies "Valid When Made" for Loans by National Banks and Federal Savings Associations

USA - June 4 2020 Last week, the Office of the Comptroller of the Currency (OCC) issued a final rule to address the legal uncertainties caused by the Second Circuit…

Makalia A. Griffith