News & Analysis as of

State Attorneys General Office of the Comptroller of the Currency

Nutter McClennen & Fish LLP

Nutter Bank Report: March 2025

The federal banking agencies have announced their intent to issue a proposal to rescind the Community Reinvestment Act (CRA) final rule originally issued in October 2023. In their announcement on March 28, the agencies also...more

Holland & Knight LLP

CFPB Grinds to a Halt: Impacts on Industry

Holland & Knight LLP on

U.S. Department of the Treasury Secretary Scott Bessent was appointed as acting director of the Consumer Financial Protection Bureau (CFPB or the Bureau) on Feb. 3, 2025. In his capacity as acting director, Bessent reportedly...more

Snell & Wilmer

Financial Institutions Heads Up: CA Legislation Pending and Potential Increasing Scrutiny

Snell & Wilmer on

In a week where the Office of the Comptroller of the Currency (OCC) has a new Acting Director, Rodney Hood, who will focus on a “balanced framework – one that fosters innovation, expands financial inclusion, and ensures all...more

Polsinelli

Scrutiny on Financial Institutions Compliance Expected to Increase During Trump Administration

Polsinelli on

Key Takeaways:  Federal bank regulators plan for vigorous review of safety and soundness and consumer compliance functions....more

Nutter McClennen & Fish LLP

Nutter Bank Report: April 2024

The CFPB has issued a policy statement that provides an analytical framework for identifying what constitutes an abusive act or practice under the Consumer Financial Protection Act of 2010 (CFPA). The new guidance published...more

Ballard Spahr LLP

SCOTUS to hear oral argument on Feb. 27 in National Bank Act preemption case

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On February 27, 2024, the U.S. Supreme Court will hear oral argument in Cantero v. Bank of America, N.A., a case involving the scope of preemption under the National Bank Act (NBA). The question before the Court is whether...more

Morgan Lewis

US State Attorneys General Seek Use of Federal Cudgel Against Banks

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The attorneys general of 20 states and territories, led by New York Attorney General Letitia James, recently sent letters to the heads of the US Consumer Financial Protection Bureau (CFPB) and US Office of the Comptroller of...more

King & Spalding

State Attorneys General Poised to Elevate Regulatory Scrutiny of Digital Asset Businesses

King & Spalding on

The Attorney General Alliance (“AGA”) recently issued a collaborative White Paper that signals heightened scrutiny of digital asset businesses by state Attorneys General in coming years. Recognizing that it is “no longer...more

Morgan Lewis - All Things FinReg

“Madden Fix” Rules Withstand a Key Test: What Happens Next

More than six years after it was decided, the practical consequences of the US Court of Appeals for the Second Circuit’s Madden v. Midland Funding, LLC decision continue to diminish. The decision—which held that, under some...more

Troutman Pepper Locke

Consumer Groups and State AGs Push Regulators to Tighten Guidance on Bank Partnerships

Troutman Pepper Locke on

On October 18, consumer advocate groups and 19 state attorneys general wrote comment letters, urging banking regulators to denounce “rent-a-bank” arrangements between financial institutions and fintechs or other third-party...more

McGlinchey Stafford

U.S. House Of Representatives Votes To Override OCC True Lender Rule

McGlinchey Stafford on

The U.S. House of Representatives on June 24th voted 218 to 208 to repeal the Office of the Comptroller of the Currency’s (OCC) “True Lender” rule under the Congressional Review Act (CRA). As discussed in earlier alerts, the...more

Ballard Spahr LLP

State AGs file opposition to FDIC’s summary judgment motion in lawsuit challenging “Madden-fix” rule

Ballard Spahr LLP on

The state attorneys general have filed their opposition to the FDIC’s motion for summary judgment in their lawsuit to set aside the FDIC’s “Madden-fix” rule.  The filing also includes the AGs’ reply to the FDIC’s opposition...more

Morrison & Foerster LLP

Financial Services Report - Spring 2021

Can you say 0 to 60? Not cars, but pretty much everything to do with financial services. A new year, a new administration, and new challenges for providers. Prior CFPB Director Kraninger is long gone. Acting Director Uejio...more

Ballard Spahr LLP

State AGs file opposition to OCC’s summary judgment motion

Ballard Spahr LLP on

The Attorneys General of California, Illinois, and New York have filed their opposition to the OCC’s cross-motion for summary judgment in their lawsuit to enjoin the OCC’s final rule (Rule) purporting to override the Second...more

Goodwin

State Attorneys General Challenge the OCC’s “True Lender” Rule

Goodwin on

As LenderLaw Watch previously reported, the Office of the Comptroller of the Currency (OCC) issued its final rule on the True Lender doctrine in October 2020, addressing ambiguity in federal law and establishing that a...more

Ballard Spahr LLP

Eight state attorneys general file lawsuit seeking to overturn OCC’s true lender rule

Ballard Spahr LLP on

On January 5, 2021, the Attorneys General of New York, California, Colorado, the District of Columbia, Massachusetts, Minnesota, New Jersey, and North Carolina filed a voluminous Complaint in federal district court for the...more

Troutman Pepper Locke

States Sue OCC, Challenging its “True Lender” Rule

Troutman Pepper Locke on

On January 5, 2021, the Attorneys General of New York, California, Colorado, the District of Columbia, Massachusetts, Minnesota, New Jersey and North Carolina (collectively, the “States”) sued the Office of the Comptroller of...more

Ballard Spahr LLP

Plaintiffs in lawsuit challenging OCC Madden-fix rule move for summary judgment

Ballard Spahr LLP on

The Attorneys General of California, Illinois, and New York have filed a motion for summary judgment in their lawsuit filed against the Office of the Comptroller of the Currency (OCC) to enjoin the OCC’s final rule purporting...more

Bradley Arant Boult Cummings LLP

State Attorneys General Challenge FDIC’s Madden Fix

In early August 2020, several state attorneys general filed suit against the Office of the Comptroller of the Currency (OCC) challenging the OCC’s proposed “Madden Fix.” Notably, while the Federal Deposit Insurance...more

Goodwin

States Challenge FDIC “Valid When Made” Rule With New Lawsuit

Goodwin on

On August 20, 2020, seven states – California, Illinois, Massachusetts, Minnesota, New Jersey, New York, and North Carolina – and the District of Columbia (together, the States) filed suit against the Federal Deposit...more

Bradley Arant Boult Cummings LLP

State Attorneys General Challenge OCC Madden Fix

Last Wednesday, the attorneys general of Illinois, California, and New York filed a lawsuit in the United States District Court for the Northern District of California challenging the Office of the Comptroller of the...more

Nutter McClennen & Fish LLP

Fintech in Brief: State Attorneys General File Lawsuit Challenging OCC’s ‘Valid When Made’ Rule

On July 29, 2020, the state attorneys general for California, Illinois, and New York filed a complaint against the Office of the Comptroller of the Currency (“OCC”) challenging the OCC’s final “valid when made” rule (the “OCC...more

BCLP

New York, California and Illinois Sue OCC to Block “Valid When Made” Rule

BCLP on

Just two months ago, the Office of Comptroller of the Currency (“OCC”) addressed the “valid when made” doctrine and held that interest rates established on bank-originated loans remain valid even after the loan is transferred...more

Cozen O'Connor

Massachusetts Attorney General Alleges Chipotle Served Up A Side Order Of Wage And Hour Violations, Reaches $2 Million Settlement

Cozen O'Connor on

Labor & Employment- Massachusetts Attorney General Alleges Chipotle Served Up a Side Order of Wage and Hour Violations, Reaches $2 Million Settlement- Massachusetts AG Maura Healey reached a settlement with casual...more

Morrison & Foerster LLP

Attorneys General Push Against OCC’s Attempts To Codify “Valid When Made” Rule

On January 21, 2020, twenty-two State Attorneys General and the Hawaii Office of Consumer Protection submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in opposition to its proposed rulemaking...more

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