State Regulators' Powers Over National Banks Reaffirmed by U.S. Supreme Court

Recently, the United States Supreme Court, in its decision styled Andrew M. Cuomo v. The Clearing House Association, L.L.C., No. 08-453, reaffirmed that federal banking regulations do not pre-empt states from enforcing their own fair-lending laws against national banks.

This dispute arose following the New York State Attorney General’s attempt to investigate several banks’ residential real-estate lending practices in 2005. The Attorney General’s office had suspected discriminatory lending practices after reviewing reports that showed minority borrowers received a larger percentage of high-interest home loans than white borrowers. As part of that probe, the Attorney General sent letters to several national banks, in lieu of a subpoena, requesting that they provide certain non-public information regarding their mortgage lending practices. In response, the federal Office of the Comptroller of the Currency (“OCC,” the chartering authority and federal regulator of national banks) and the Clearing House Association (a banking trade group) sued to block the Attorney General’s investigation, claiming that an OCC regulation promulgated under the National Bank Act pre-empted any state regulation or enforcement against national banks.

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Welcome to the Consumer Financial Services Blog

Which among the following businesses are potentially subject to consumer financial services laws, rules, and regulations?

A. a retail clothing chain
B. a bank or mortgage company
C. an internet retailer
D. a fast food franchisor
E. all of the above

If you answered E, “All of the above,” you are CORRECT. However, many companies do not realize their businesses are subject to consumer financial services laws and, consequently, their businesses may not be compliant.

The focus of the Consumer Finance Law Blog is to keep – all on one site – "non-traditional financial service providers," such as retailers, potentially subject to consumer financial services laws abreast of recent developments in:

  • State consumer protection statutes and regulations
  • State privacy statutes
  • Privacy and consumer protection litigation
  • Card Association Rules
  • Equal Credit Opportunity Act
  • Electronic Funds Transfer Act
  • Fair Credit Reporting Act
  • Fair Credit Transactions Act
  • Fair Debt Collection Practices Act
  • Fair Housing Act
  • Gramm Leach Bliley Act
  • National Automated Clearing House Association Rules
  • Payment Card Industry Data Security Standard
  • State Money Transmitter Statutes
  • State Retail Installment Sales Act
  • State and Federal Unfair and Deceptive Trade Practices Acts
  • TILA, RESPA, and related federal and state consumer disclosure and notice requirements

Kelley Drye & Warren LLP’s Consumer Financial Services practice and the editors of this Blog – Donna Wilson, Joel Hewer, and John McGuinness, with invaluable contributions from analyst Michael McGinn – welcome you and hope that you find our posts interesting, educational, and thought provoking. We also welcome your feedback and invite you to suggest topics or recent decisions of interest that you would like us to address.