The Situation: On December 18, 2020, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the Board of Governors of the Federal Reserve System (the "Federal Banking Agencies") jointly...more
On November 18, 2019, the Office of the Comptroller of the Currency ("OCC") and the Federal Deposit Insurance Corporation ("FDIC") issued proposed rules ("Proposed Rules") that reaffirm the "valid-when-made" doctrine in...more