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, inappropriately shielding national banks from state consumer financial laws that apply to similarly situated state-chartered banks and state-licensed nonbank firms.

OCC Preemption News

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

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