The "Madden Fix" rules were introduced by the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC) in 2020 to address legal uncertainty caused by the 2015 Madden v. Midland Funding decision. This decision held that loans sold by national banks to non-banks could be subject to state usury laws, casting aside the long-standing "valid when made" doctrine. This doctrine states that a loan, if valid when originated by a bank, retains that validity even when sold to a non-bank. The new rules reinstated the "valid when made" principle, allowing loans originated by banks at lawful interest rates to maintain those rates even after being sold or transferred. This provided clarity and security to the loan market, particularly secondary buyers and bank partnerships. In early 2022, the U.S. District Court for the Northern District of California upheld the OCC and FDIC's rules, rejecting challenges from state attorneys general who argued that the rules exceeded the agencies' authority and encouraged predatory lending practices. Despite this ruling, the issue of the "true lender" doctrine remains unresolved. This doctrine examines whether the originating bank or a partnering non-bank entity is the actual lender, which affects regulatory responsibility. With no clear federal standard on this, the focus now shifts toward scrutinizing these bank-partnership models more closely. While the district court’s decision offers more stability for now, the question of who the true lender is in these transactions remains a potential risk, as state and federal regulators continue to scrutinize these relationships.