News & Analysis as of

Preemption Banks Financial Institutions

Troutman Pepper Locke

Preemption Win for Federal Credit Union in the Ninth Circuit on Bounced Check Fee Claims

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In a significant ruling, the U.S. Court of Appeals for the Ninth Circuit affirmed the dismissal of a consumer’s state law claims against a federal credit union on federal preemption grounds. The putative class action...more

Cadwalader, Wickersham & Taft LLP

Heating Up, June 2025 - OCC Defends Federal Bank Preemption

In response to a request from the Conference of State Bank Supervisors (“CSBS”), Acting Comptroller of the Currency, Rodney E. Hood, decisively defended OCC regulations regarding the ability of national banks and Federal...more

Sheppard Mullin Richter & Hampton LLP

OCC Rejects Calls to Roll Back Preemption Rules

On June 9, Acting Comptroller of the Currency Rodney Hood issued a letter rejecting the Conference of State Bank Supervisors’ (CSBS) request that the OCC rescind its 2011 preemption regulations. The OCC ‘s letter signals...more

Ballard Spahr LLP

Illinois swipe fee injunction extended to cover out-of-state banks, but not federal credit unions

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Chief Judge Virginia Kendall of the Northern District of Illinois has extended her preliminary injunction prohibiting Illinois from enforcing the Illinois Interchange Fee Prohibition Act (the “IFPA”) to cover out-of-state...more

Moore & Van Allen PLLC

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

Moore & Van Allen PLLC on

For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

Ballard Spahr LLP

Court grants partial injunction for National Banks and Federal Savings Associations in the lawsuit challenging the Illinois...

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In a 37 page order, Chief Judge Virginia M. Kendall in the Northern District of Illinois determined that the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union...more

WilmerHale

The Bank Preemption Ripple Effects After Cantero, Flagstar

WilmerHale on

On May 30, the U.S. Supreme Court issued a unanimous decision in Cantero v. Bank of America, vacating and remanding a decision by the Second Circuit that concluded that the federally authorized powers of national banks under...more

Ballard Spahr LLP

Bank and Credit Union Industry Groups Challenge Illinois Interchange Fee Prohibition Act as Unlawful and Urge the Court to Stop...

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On August 15, 2024, the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union League filed a complaint for declaratory and injunctive relief against the Illinois...more

Ballard Spahr LLP

Three Members of Congress and U.S. Treasury Express Concerns that Florida Law Prohibiting Banks from Considering Customers’...

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As we previously blogged, a Florida law (Fla. Stat. § 655.0323, entitled “Unsafe and unsound practices”) which became effective July 1, 2024 prohibits federal and state depository institutions conducting business in the state...more

Ballard Spahr LLP

OCC to review its preemption interpretations in light of Supreme Court opinion and state debanking laws

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On July 17, Acting Comptroller of the Currency Michael Hsu delivered prepared remarks before the Exchequer Club entitled “Size, Complexity, and Polarization in Banking.”...more

Ballard Spahr LLP

By Passing Buck to Second Circuit, Supreme Court Leaves National Bank Preemption in Limbo

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On this coming Thursday, July 11, from Noon until 1 pm, ET, we will be holding a Webinar Roundtable about the Supreme Court’s recent opinion on May 30, in which a unanimous Supreme Court reversed and remanded the Cantero v....more

Troutman Pepper Locke

Trade Organizations Challenge Colorado’s DIDMCA Opt-Out Legislation in Federal Court

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Monday, three trade organizations filed a complaint in Colorado federal court challenging H.B. 1229, Colorado’s effort to limit interest charges by out-of-state financial institutions, which is set to take effect on July 1,...more

Ballard Spahr LLP

More States Mull Interest Rate Preemption and “Anti-Evasion” Legislation

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Rhode Island, Minnesota, and Nevada have joined the list of jurisdictions considering proposals to legislatively opt out of federal interest rate preemption established under the federal Depository Institutions Deregulation...more

Troutman Pepper Locke

Amici Argue for Narrow Interpretation of National Bank Act Preemption

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A group of non-profit consumer advocacy organizations, the Conference of State Bank Supervisors, and the American Association of Residential Mortgage Regulators filed two separate briefs asking the U.S. Supreme Court to...more

Troutman Pepper Locke

Oregon Banks and Trade Association File Declaratory Action Requesting Relief from State Legislation Alleged to be Retroactively...

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On August 13, 2020, the Oregon Bankers Association (“OBA”) and three Oregon-chartered banks filed a Complaint for declaratory and injunctive relief against the State of Oregon, Oregon’s Attorney General, and the Director of...more

Skadden, Arps, Slate, Meagher & Flom LLP

District Court Applies Section 546(e) Safe Harbor to Customer of Financial Institution, Revitalizing Key Defense

A recent decision from the U.S. District Court for the Southern District of New York has breathed new life into the Bankruptcy Code Section 546(e)’s securities transaction safe harbor for fraudulent conveyance actions. Judge...more

Holland & Knight LLP

Food and Beverage Law Update: June 2018

Holland & Knight LLP on

Wage and Hour - Decision Upholds Class Action Waivers in Arbitration Clauses, Resolves Circuit Split - The U.S. Supreme Court issued a long-awaited decision in Epic Systems Corp. v. Lewis on May 21, 2018, holding that...more

Morrison & Foerster LLP

Financial Services Report - Spring 2017

EDITOR’S NOTE - In like a lion, out like a lamb—it works for weather; does it work for new administrations? We’ll have to wait and see. We’ll have to wait and see about the length of CFPB Director Richard Cordray’s...more

Orrick, Herrington & Sutcliffe LLP

Class Action Against Lending Club and WebBank Headed to Defeat

On Monday, a federal district court in the Southern District of New York granted a motion to compel arbitration in Bethune v. Lending Club Corporation, et al., a closely watched putative class action raising important issues...more

Orrick - Finance 20/20

FHFA’s $32 Billion RMBS Claims Are Not Time-Barred

On August 21, 2015, Judge Alvin Thompson of the United States District Court for the District of Connecticut denied Royal Bank of Scotland Group PLC’s (“RBS”) motion for summary judgment as to claims brought by the Federal...more

Cadwalader, Wickersham & Taft LLP

The Second Circuit Denies Midland’s Request For Rehearing On Its Decision That Upended Longstanding Principles of Lending Law

On August 12, 2015, the United States Court of Appeals for the Second Circuit denied Midland Funding, LLC and Midland Credit Management (collectively, “Midland”)’s petition for panel rehearing, or, in the alternative,...more

Ballard Spahr LLP

Federal, State Law Preempts New York City Responsible Banking Act, Federal Court Rules

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New York City’s Responsible Banking Act (RBA) is preempted by federal and state law, a federal court has ruled. Pursuant to the New York City Charter, only financial institutions that are designated “deposit banks” by the...more

Orrick - Finance 20/20

5th Circuit Revives FDIC’s Suit Against Goldman, Deutsche Bank, and Royal Bank of Scotland

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On August 10, 2015, the Fifth Circuit revived a securities fraud suit brought by the Federal Deposit Insurance Corporation (“FDIC”) as receiver for Guaranty Bank against Goldman Sachs & Co., Deutsche Bank AG, and the Royal...more

Orrick, Herrington & Sutcliffe LLP

Treasury Request for Public Input on Expanding Access to Credit through Online Marketplace Lending

On July 20, the Department of the Treasury published a Notice and Request for Information (“RFI”) seeking comment on various aspects of online marketplace lending, including – - the business models and products offered...more

Davis Wright Tremaine LLP

Increased Risk for Buyers of Credit Card Loans

Third party debt buyers may face increased threat of state-law class action lawsuits after a recent Second Circuit ruling prohibiting such debt buyers from invoking federal preemption defenses under the National Bank Act to...more

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