b'to the consumer in terms of privacy and data security,uncertainty created by the Second Circuits decision and expects to commence a rulemaking process in thein Madden v. Midland Funding, LLC, No. 14-2131, which spring of 2022. held that assignees of a national bank were not allowed to charge interest at the rate permitted by the assignor national banks state. This ruling called into question The Madden Fix Lawsuitsthe longstanding Valid When Made Doctrinethat As noted in Goodwins 2020 Year In Review, ina transaction valid when made remains valid upon June 2020 the OCC and Federal Deposit Insurancetransfer. In early June 2020, the OCC issued a final rule Corporation (FDIC) each issued a final rule in an effortclarifying that as a matter of Federal law, banks may to address the legal confusion regarding the impacttransfer their loans without impacting the permissibility of the permissible interest when a bank transfers aor enforceability of the interest term. Shortly thereafter, loan to a third party. The rules were in response tothe FDIC issued its own rule adopting the Valid When Made Doctrine. Proportion of State-Federal ActionsFederal State Joint8% 5% 6% 17% 6% 2%32% 33% 32%43% 44%38%60% 53% 60% 45% 61% 50%2016 2017 2018 2019 2020 202159'