OCC Preemption
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.

OCC Preemption News

Comment Letter

AARMR, CSBS, NCSL Extension Request OCC

Download the Full Comment Letter [PDF] Chief Counsel’s Office Attention: Comment Processing, Office of the Comptroller of the Currency 400 7th Street, SW, Suite 3E-218 Washington, DC 20219 Attention: Comments (OCC-2025-0735) Re: Preemption Determination: State Interest-on-Escrow Laws (RIN 1557-AF45) The Conference of State Bank Supervisors (“CSBS”) , National Conference of State Legislatures (“NCSL”), and the American Association of Residential Mortgage
January 15, 2026
Comment Letter

Extension Request - National Bank Chartering

Download the Full Comment Letter [PDF] Chief Counsel’s Office Attention: Comment Processing, Office of the Comptroller of the Currency 400 7th Street, SW, Suite 3E-218 Washington, DC, 20219 Attention: Comments (OCC-2025-0768) Re: National Bank Chartering (RIN 1557-AF47) The Conference of State Bank Supervisors (“CSBS”)1 requests that the Office of the Comptroller of the Currency (“OCC”) extend the comment deadline for
January 13, 2026
Comment Letter

Request for Information: Deregulation

Download the Full Comment Letter [PDF ] The Honorable Russel T. Vought Director Office of Management and Budget 725 17th Street NW Washington, DC 20503 Docket No. OMB-2025-0003 Re: Request for Information: Deregulation Dear Director Vought: In response to the Office of Management and Budget’s (“OMB”) Request for Information: Deregulation, the Conference of State Bank Supervisors (“CSBS”) has attached letters
May 15, 2025
Comment Letter

Rescission of OCC Preemption Regulations

The Honorable Rodney Hood Acting Comptroller of the Currency Office of the Comptroller of the Currency 400 7 th Street SW Washington, DC 20219 Re: Executive Orders 14219 and 14267 – Rescission of OCC Preemption Regulations Dear Acting Comptroller Hood: On behalf of the Conference of State Bank Supervisors (“CSBS”), I request that the Office of the Comptroller of the
May 8, 2025
Press Room

OCC Should Rescind Unlawful Preemption Rules

Washington, D.C. - Recent Executive Orders compel the Office of the Comptroller of the Currency (OCC) to rescind its preemption regulations, the Conference of State Bank Supervisors (CSBS) said today in a letter to Acting Comptroller Rodney Hood. “The OCC’s preemption regulations are clearly unlawful, inconsistent with Supreme Court rulings
May 8, 2025
Comment Letter

OCC 5-Year Review of Preemption

CSBS believes this review is long overdue, and we stand ready to assist as you undertake the processes mandated by the Dodd-Frank Act.
July 28, 2024
Comment Letter

National Banks and Federal Savings Associations as Lenders

September 3rd, 2020 Office of the Comptroller of the Currency Chief Counsel’s Office 400 7th Street, SW, Suite 3E-218 Washington, DC 20219 Docket ID OCC-2020-0026 Re: National Banks and Federal Savings Associations as Lenders. Dear Sir or Madam, The Conference of State Bank Supervisors (“CSBS”) 1 appreciates the opportunity to comment on the Notice of proposed rulemaking issued by the
September 3, 2020

All Issues