This policy brief examines several failures by the Office of the Comptroller of the Currency (OCC) to comply with the Dodd-Frank Act and other legal authorities governing the scope of preemption for national banks and federal savings associations. The policy brief argues that the OCC should promptly rescind or revise several of its existing rules, policies, and legal interpretations to bring those materials into compliance with the Dodd-Frank Act and other applicable laws.
GW Paper Series
Wilmarth, Arthur E. Jr., "Policy Brief: The OCC’s Repeated Failures to Comply with the Dodd-Frank Act and Other Legal Authorities Governing the Scope of Preemption for National Banks and Federal Savings Associations" (2021). GW Law Faculty Publications & Other Works. 1571.