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Exception Tracking Spreadsheet (TicklerTrax™)
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OCC issues interpretation of preemption standards

The OCC has issued an interpretation of 12 U.S.C. 25b, which codifies preemption standards and established procedural requirements for certain preemption actions by the agency. Federal preemption permits national banks and federal savings associations, many of which operate across state lines, to operate under a uniform set of rules to support nationwide banking. The OCC concluded that the federal banking system, and its customers, would benefit from a comprehensive interpretation of these provisions, which sets out a consistent framework for compliance.

The OCC's Interpretive Letter 1173, issued on December 18, 2020, discusses, among other topics:

  • Standards for preemption of state consumer financial laws
  • State law preemption no requiring a statutory "preemption determination"
  • Preemption determinations under the Barnett standard
  • Preservation of powers related to charging interest
  • Deference
  • The OCC Framework for Compliance
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