News & Analysis as of

DIDMCA

Ballard Spahr LLP

Colorado Files Opposition to Plaintiffs’ Rehearing Petition in Opt-Out Litigation

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As we reported previously, a petition for rehearing en banc was filed by the plaintiff bank trade associations in National Association of Industrial Bankers v. Weiser. In that case, the panel’s 2-1 decision held that a loan...more

Orrick, Herrington & Sutcliffe LLP

Colorado argues against en banc review in DIDMCA opt-out legislation challenge

On January 21, representatives from Colorado filed a response in the U.S. Court of Appeals for the 10th Circuit opposing a petition for rehearing en banc in a case involving the state’s opt-out from federal interest rate...more

Orrick, Herrington & Sutcliffe LLP

Bank Petitions Tenth Circuit for en Banc Review of Fed’s Power to Deny Master Accounts

On December 15, a Wyoming-chartered bank petitioned for rehearing en banc in the U.S. Court of Appeals for the 10th Circuit, challenging the court’s earlier decision that upheld the Fed’s discretion to deny master account...more

Orrick, Herrington & Sutcliffe LLP

Tenth Circuit Receives Three Briefs Supporting Plaintiffs’ Petition for Rehearing en Banc in a Case Involving Colorado’s DIDMCA...

On December 16, the OCC, the FDIC, and 20 state attorneys general filed a trio of briefs in support of the plaintiffs’ petition for rehearing en banc in the U.S. Court of Appeals for the 10th Circuit....more

Ballard Spahr LLP

Colorado “Opt-Out” Litigation – Petition for Rehearing En Banc And Amicus Briefs in Support

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As we previously reported, on November 10, 2025 the Tenth Circuit rendered its 2-1 decision in National Association of Industrial Bankers v. Weiser. It held that a loan is “made” for purposes of the opt-out provision in...more

Orrick, Herrington & Sutcliffe LLP

Fed Requests Comment on the Future of Agency’s Check Services

On December 9, the Fed published an RFI in the Federal Register requesting public input on the future of the Fed’s check services. In its notice, the Fed will assess possible strategies for the future of checks, acknowledging...more

Husch Blackwell LLP

Petition for Rehearing Filed in Colorado DIDMCA Opt-Out Case

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A group of trade associations has filed a petition for rehearing en banc asking the Tenth Circuit to review a panel decision holding that a state’s right to opt out under Section 525 of the federal Depository Institutions...more

Cadwalader, Wickersham & Taft LLP

Tracing Trends, November 2025 - Colorado’s Opt-Out From State Bank Exportation of Interest Rates is Live

As of last week, Monday, November 10th, the Tenth Circuit has rescinded a preliminary injunction against a Colorado state law opting-out from DIDMCA and remanded the case back to the United States District Court for the...more

Katten Muchin Rosenman LLP

New Concerns for Bank Fintech Partnerships: 10th Circuit's DIDMCA Decision Is the First Ripple in an Anticipated Wave

Issued on November 10, 2025, the long-awaited decision from the US Court of Appeals for the 10th Circuit1 in National Association of Industrial Bankers v. Weiser supports Colorado's exercise of its 2023 legislative...more

Ballard Spahr LLP

National Association of Industrial Bankers v. Weiser: Implications of the Tenth Circuit’s ruling that Colorado interest rate...

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On November 10, 2025, the U.S. Court of Appeals for the Tenth Circuit, in a 2–1 decision, issued its opinion in National Association of Industrial Bankers et al. v. Weiser. In resolving what it described as “an issue of...more

Sheppard Mullin Richter & Hampton LLP

Tenth Circuit Allows Colorado to Enforce its Interest Rate Caps on Out-of-State Banks

In a significant decision for bank partnership arrangements, the United States Court of Appeals held that Colorado may apply its state interest rate caps to loans made by out-of-state banks under the Depository Institutions...more

Orrick, Herrington & Sutcliffe LLP

Tenth Circuit Narrows Scope of State Bank Rate Preemption

On November 10, the U.S Court of Appeals for the 10th Circuit reversed a district court decision that had enjoined the State of Colorado from enforcing its state usury laws against state-chartered banks located outside of...more

Mayer Brown

DIDMCA Opt-Out Update—Tenth Circuit Reverses Colorado Preliminary Injunction

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Litigation involving Colorado’s opt-out from the interest exportation provisions of the Depository Institutions Deregulation and Monetary Control Act of 1980 (DIDMCA) has taken an adverse turn for the financial services...more

Troutman Pepper Locke

Tenth Circuit Narrows DIDMCA Opt‑Out Preemption: Colorado May Apply Its Rate Caps to Loans From State Chartered Banks to Borrowers...

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On November 10, the Tenth Circuit reversed the district court’s preliminary injunction in the challenge to Colorado’s H.B. 23‑1229, holding that Colorado may enforce its Uniform Consumer Credit Code (UCCC) interest‑rate caps...more

Sheppard Mullin Richter & Hampton LLP

FDIC Withdraws Support for Colorado’s Opt-Out Law Before Tenth Circuit

On February 26, the FDIC withdrew its amicus brief in the 10th Circuit Court of Appeals challenging Colorado’s 2023 opt-out law which aimed to restricting higher-cost online lending. The FDIC’s decision follows a shift in the...more

Ballard Spahr LLP

Oregon Considering DIDMCA Opt-Out Legislation

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Oregon may become the latest state attempting to stop out-of-state banks from “exporting” home-state interest rates on loans made to Oregon consumers. Like similar legislation adopted by Colorado in 2023, House Bill 2561...more

Troutman Pepper Locke

Troutman Represents all Fifty States Bankers Associations and D.C. in Tenth Circuit DIDMCA Opt-Out Litigation

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In the last two weeks, several amicus briefs were filed in the Tenth Circuit in the ongoing litigation concerning Colorado’s opt-out from the Depository Institutions Deregulation and Monetary Control Act (DIDMCA). Troutman...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter - October 2024

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper Locke

States Join Colorado in Defense of Interest Rate Opt-Out Law

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On September 20, 13 states and Washington, D.C. joined Colorado in its appeal asking the Tenth Circuit to uphold a state law imposing more restrictive interest rate caps on loans from out-of-state banks to residents, arguing...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Have State-Chartered, FDIC-Insured Banks Finally Achieved Interstate Usury Parity with...

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In today’s podcast, which repurposes a recent webinar, we examine the impact, if any, of a landmark opinion rendered by Judge Daniel Domenico of the Federal District Court for the District of Colorado in a case challenging...more

Ballard Spahr LLP

Plaintiffs oppose Colorado’s motion for a stay of the preliminary injunction in the Colorado opt-out litigation

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Very soon, briefing by the parties in the 10th Circuit will commence with respect to Colorado’s appeal of a preliminary injunction entered by the Federal District Court for the District of Colorado. The District Court...more

Ballard Spahr LLP

Tenth Circuit sets briefing schedule in appeal from preliminary injunction granted to trade groups with respect to Colorado...

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We are following very closely this appeal to the 10th Circuit of the preliminary injunction issued by the Federal District Court for the District of Colorado to the plaintiffs (three trade groups) enjoining the Colorado...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part II

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The 1978 landmark opinion in Marquette National Bank v. First of Omaha Service Corp held that under the National Bank Act, a national bank has the right to export the interest rate authorized by the state where the bank is...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Interest Rate Exportation Under Attack Part I

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The 1978 landmark opinion in Marquette National Bank v. First of Omaha Service Corp held that under the National Bank Act, a national bank has the right to export the interest rate authorized by the state where the bank is...more

Ballard Spahr LLP

Plaintiffs file amended complaint in Colorado opt-out litigation

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Here is an update on the lawsuit filed by three trade associations against the Colorado Attorney General and UCCC Administrator challenging the application of the Colorado opt-out statute to out-of-state, state chartered,...more

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