The Valid When Made Rule: A Decade After Madden

The Valid When Made Rule: A Decade After Madden

From AFSA Extra Credit Podcast by American Financial Services Association

October 9, 2025 · 27 min · Season 4 · Episode 15

About this episode

The episode discusses the Valid When Made Rule and its implications a decade after the Madden v Midland Funding case.

In this episode of the AFSA Extra Credit Podcast, Dan steps aside to let experts take care of a complex legal topic – the Valid When Made Rule. As the Madden v Midland Funding (2015) case turns 10, Steve Obermeier and Jeremy Broggi, Partners with Wiley Rein and Frank Borchert, former CLO/CAO/CRO with Best Egg provide an overview on the rule and walk through some of the history. Then, they talk about the federal regulatory and judicial responses to the decision, before turning to the broader industry implications. They also offer some practical takeaways for listeners. Learn more about Wiley Rein at wiley.law . Listen to the episode anywhere you get podcasts or visit afsaonline.org/podcasts . Speakers Jeremy Broggi , Partner at Wiley Rein LLP Frank Borchert , former CLO/CAO/CRO at Best Egg Host Steve Obermeier , Partner at Wiley Rein LLP ----------------------------- Don't forget to follow AFSA on Twitter @AFSA_DC and @AFSA_SGA and on Linkedin. The blog at afsaonline.org is also a great resource for the most up-to-date news. If you've got questions or you'd like to suggest a guest, please shoot us an email at membership@afsamail.org or tweet at us.

People in this episode

Host: Steve Obermeier

Guests: Jeremy Broggi, Frank Borchert

Topics covered

  • Valid When Made Rule
  • Madden v Midland Funding
  • legal implications
  • federal regulatory responses
  • industry implications
  • practical takeaways

Keywords

  • Valid When Made Rule
  • Madden v Midland Funding
  • legal topic
  • federal regulation
  • industry implications
  • financial services

Mentioned in this episode

Organizations: Wiley Rein, Best Egg, American Financial Services Association

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