On Tuesday, January 21st, SFA and the Bank Policy Institute (BPI) submitted a joint letter to the Office of the Comptroller of the Currency (OCC) on its Valid-When-Made proposed rule. Our letter supports the OCC’s effort to address the market uncertainty due to the Madden ruling by affirming existing law as to the validity of a loan’s interest rate terms once a loan has been sold, assigned or otherwise transferred. SFA will also be commenting on the FDIC’s proposal, too, due February 4^th, via our Valid-When-Made Task Force.  If you’re interested in joining SFA’s Valid-When-Made Task Force, please contact the SFA Team.