Position Summary
Wholesale preemption of state laws poses risks to consumers and financial stability. To address these risks, Congress established an unambiguous standard as to when the OCC may preempt a state consumer financial law and the process they must follow to implement this preemption standard. The OCC has failed to adhere to these strict requirements and CSBS has consistently called for the OCC to rescind and reissue its preemption regulations to align with the law.
COMMENT LETTER
OCC IFR: National Bank Non-Interest Charges and Fees