Preemption also includes an "except" statement -- except where federal law or regulation requires compliance with state law. This an example.
What preemption does, however, is allow a national bank to export the rates of its home state to other states without regard to the laws of those other states (in general).
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8