On December 18, 2020, the OCC released a new interpretation of the statutory standards and requirements for federal preemption of state consumer financial laws that were enacted as part of the Dodd-Frank Act. Section 1044 of Dodd-Frank, codified at 12 U.S.C. § 25b, contains both substantive and procedural preemption provisions.  The OCC’s Interpretive Letter 1173 (“IL … Continue Reading