NCLC submitted comments on the Office of the Comptroller of the Currency’s (OCC) proposed interest-on-escrow preemption determination and real estate lending escrow accounts rule, which exceed the agencyʼs power.
Read More about Comments on OCC Interest-on-Escrow Law Preemption
Bank Regulator Should Abandon Plan to Let Banks Keep Interest on Homeowners’ Escrow Accounts
Read More about Proposal Would Allow Banks to Charge Homeowners Hidden Fees and Override State Laws
NCLC joined a letter opposing adding a provision to the National Defense Authorization Act (NDAA) that would preempt state laws on artificial intelligence (AI).
Read More about Letter Opposing Adding Preemption of AI Laws to NDAA
The rental housing crisis continues to squeeze working families. Contributing to these struggles is the use of tenant screening reports, which typically combine information about eviction filings, criminal records, and credit history. These reports often contain significant systemic errors and problems, such as This Policy Brief offers solutions as to what states can do to…
Read More about What States Can Do to Regulate Tenant Screening
In connection with the OCC’s review of regulations under the Economic Growth and Regulatory Paperwork Reduction Act of 1996 (EGRPRA), NCLC and other consumer groups urged the OCC to rescind its preemption regulations and its “valid-when-made” interest rate regulation, and to update its national bank charges regulation.
Read More about Comments to OCC on EGRPRA Review of Preemption and Fee Regulations
This brief argues that a state that opts out of DIDMCA may enforce its interest rate laws against out-of-state, state-chartered banks in order to stop rent-a-bank lending and other high-cost loans that exceed state rate caps.
Read More about Amicus Brief: NAIB v. Weiser (10 Circuit, DIDMCA opt out)
NCLC, joined by several consumer organizations, sent a letter urging the Office of the Comptroller of the Currency (OCC) to immediately rescind the OCC’s rules, interpretations, bulletins and opinions preempting state consumer financial laws, as they are not in compliance with the Dodd-Frank Wall Street Reform and Consumer Protection Act of 2010 or the Supreme…
Read More about Letter Urging OCC to Rescind Preemption Regulations
We are supporting District of Columbia bill B25-0609 Protecting Affordable Loans Amendment Act of 2023, which opts DC out of federal law that allows out-of-state, state-chartered banks to export their home state interest rate limits into DC.
Read More about Testimony in Support of DC B25-0609 Protecting Affordable Loans Amendment Act
As written, this bill would harm consumers and aid scammers by making it more difficult to challenge fraud involving electronic records and electronic signatures. The bill preempts consumer-friendly state laws without establishing reasonable protections on the federal level.
Public Citizen, Consumer Federation of America, National Association of Consumer Advocates, National Consumer Law Center, and Public Justice submitted an amicus brief in support of petitioners in Cantero v. Bank of America. The brief argued that the Second Circuit erred in finding that state mortgage escrow interest laws are preempted and in applying a preemption…
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…
Read More about Group Comments on OTS Integration; Dodd-Frank Implementation
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…
Read More about OCC Ignores Dodd-Frank Act’s Repeal of 2004 Preemption Regulations
