On December 30, 2025, the Office of the Comptroller of the Currency (OCC) requested comment on two proposals: a new rule regarding mortgage escrow accounts, and a determination that federal law preempts state laws requiring banks to pay interest on mortgage escrow accounts.
The National Consumer Law Center submitted comments on both proposals on behalf of our low-income clients. Because these two proposals are so closely related, we commented on them together and submitted these comments to both dockets.
We strongly oppose the OCCʼs proposals and urge the OCC to withdraw them. They are contrary to federal law, outside of the OCCʼs authority, do not meet the requirements of the National Bank Act, including the preemption standard set forth in Barnett Bank, will reduce price transparency, will create an unlevel playing field for competition, and will make homeownership more expensive for consumers.
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