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The Curious Case of Madden v. Midland Funding and the Survival of the Valid-When-Made Doctrine, North Carolina Banking Institute Journal

January 01, 2017

In May 2015, the U.S. Court of Appeals for the Second Circuit handed down a curious decision, Madden v. Midland Funding, LLC,1 that many in the banking industry believe has challenged a longstanding and fundamental principle of American bank usury law, namely, the principle of “valid-when-made.”

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