In 2004, the Office of the Comptroller of the Currency (OCC) adopted sweeping regulations preempting state laws aimed at abusive bank practices involving mortgages, credit cards, and other areas. The Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 effectively overturned those regulations and limited the OCC’s ability to preempt state laws.
On May 25, 2011, the OCC responded by proposing only superficial changes to the 2004 regulations and by continuing to give unfair bank practices immunity from state consumer protection laws. The OCC ignored numerous provisions of Dodd-Frank that prohibit the OCC from continuing its preemption regulations.