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Preemption Financial Institutions

Foley & Lardner LLP

The Executive Order Guaranteeing Fair Banking for All Americans and Its Implications for State Regulation of Insurance Trade...

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On August 7, 2025, the White House issued an Executive Order titled “Guaranteeing Fair Banking for All Americans,” which is intended to address instances of unfair discrimination in banking decisions by financial institutions...more

Orrick, Herrington & Sutcliffe LLP

Ninth Circuit sides with credit union after finding NCUA regulations preempted California state law

On August 1, the U.S. Court of Appeals for the 9th Circuit affirmed the dismissal of claims under California’s Unfair Competition Law (UCL) against a federal credit union, holding that federal law preempts state regulation of...more

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

Nutter McClennen & Fish LLP

Nutter Bank Report: June 2025

The Federal Reserve has announced that the agency will no longer assess reputational risk when examining banks’ risk management processes. According to the June 23 announcement, the Federal Reserve has already begun reviewing...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

Orrick, Herrington & Sutcliffe LLP

District court receives motion for preliminary injunction in Illinois interchange fee suit

On March 17, a group of banking and credit union trade associations (the plaintiffs) filed a motion for summary judgment in the U.S. District Court for the Northern District of Illinois, arguing the Illinois Interchange Fee...more

Ballard Spahr LLP

Wisconsin Appeals Court Rejects National Bank Act Preemption

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In a significant ruling on February 18, 2025, the Wisconsin Court of Appeals determined that National Bank Act (NBA) does not preempt the procedural “right to cure” notice requirements mandated by the Wisconsin Consumer Act...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

Blank Rome LLP

Illinois Loses First Shot at Interchange Fees on State and Local Taxes

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Illinois enacted a law that prohibits a credit card holder’s bank from charging or receiving interchange fees on the portions of transactions that include Illinois state or local taxes and gratuities, in effect starting July...more

Moore & Van Allen PLLC

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

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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

Latham & Watkins LLP

The Tides Are Changing (Again) for US “Fair Access” and “Anti-Debanking” Laws

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“Fair access” banking laws, at the epicenter of the debates between ESG and “anti-woke” regulation and federal/state preemption, may see a resurgence under the incoming administration. In recent years, the landscape of...more

Jones Day

Boston Generating: Second Circuit Triples Down on Its Holding that Transfers Made Under Securities Contracts Are Safe Harbored in...

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Section 546(e) of the Bankruptcy Code's "safe harbor" provision (which shields transactions from avoidance claims in bankruptcy of certain securities, commodity, or forward-contract payments) has long been a magnet for...more

WilmerHale

The Bank Preemption Ripple Effects After Cantero, Flagstar

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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

Petition for rehearing to be filed in Ninth Circuit in National Bank Act preemption case related to mortgage escrow accounts

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On August 27, we blogged about the Ninth Circuit unpublished panel opinion in Kivett v. Flagstar Bank issued upon remand of the case from the Supreme Court with instructions to follow the guidance of the Supreme Court...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

Venable LLP

It Depends: Scouring Precedent to Analyze National Bank Act Preemption

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The issue before the Supreme Court in Cantero v. Bank of America was straightforward: does the National Bank Act preempt a New York state law requiring all banks, including national banks, to pay interest on certain mortgage...more

Skadden, Arps, Slate, Meagher & Flom LLP

Supreme Court Clarifies Standard for Analyzing National Bank Act Preemption

In Cantero v. Bank of America, the U.S. Supreme Court clarified the standard for analyzing whether the National Bank Act (the NBA) preempts state laws regulating banks chartered under the NBA. In doing so, the Court rejected...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: The U.S. Supreme Court’s Pending Ruling on National Bank Preemption: A Discussion of...

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On February 27, 2024, the U.S. Supreme Court heard oral argument in Cantero v. Bank of America, N.A., a case involving the effect of the Dodd-Frank Act on the scope of preemption under the National Bank Act (NBA). The...more

Ballard Spahr LLP

Opt-out challenge case assigned to Colorado federal Judge Daniel D. Domenico

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As we previously reported, on March 25, 2024, three consumer financial services industry trade groups filed a lawsuit in federal district court in Colorado challenging legislation recently adopted to opt out of rate...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

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