The National Consumer Law Center (on behalf of its low income clients), the Center for Responsible Lending, the Consumers Union, Public Citizen, and the Sargent SHriver National Center on Poverty Law submitted comments to the Office of the Comptroller of the Currency’s proposed Dodd-Frank Act Implementation regulations, in particular the provisions relating to preemption of state law and the OCC’s exclusive visitorial powers.
The proposed rules would continue the OCC’s broad preemption of state laws governing mortgages, credit cards, bank accounts, and other banking products. Continuation of those rules ignores the requirements of the Dodd-Frank Wall Street Reform and Consumer Protection Act, which restored the important role of states in protecting consumers. The visitation regulations also impermissibly narrow the range of enforcement actions states may take. We therefore respectfully urge that the OCC withdraw the current proposal, repeal the current preemption regulations, amend the visitation regulations, and proceed in accordance with the procedural and substantive requirements of the Dodd-Frank Act.