This written testimony was presented on April 26, 2007, at a hearing on "Credit Card Practices: Current Consumer and Regulatory Issues," before the Subcommittee on Financial Institutions and Consumer Credit of the U.S. House of Representatives Committee on Financial Services. The testimony...

This comment letter responds to a proposed rule issued by the Office of the Comptroller of the Currency (OCC), which would “codify” an alleged federal common-law “principle” known as “valid-when-made.” The proposed rule would amend two of the OCC's regulations – 12 C.F.R. 7.4001...