Love, Pranams, and Tashi Delek,
TOOJT
The time is out of joint; O curs'd spite, That ever I was born to set it right! (Hamlet, 1.5)
“As you know, the Comptroller of the Currency has recently issued sweeping regulations that seek to preempt almost all state laws that apply to national banks and their subsidiaries. This regulation also tries to shield all national banks - and their subsidiaries - from oversight, inspection and enforcement actions by any state authority, including the state attorneys general.
The Comptroller has said that these new regulations are merely the next natural step in that agency's interpretation of . . . Gramm-Leach-Bliley. The Comptroller has also said that these changes are incremental in nature and unlikely to have major effects on the banking industry or on consumers' experiences with financial institutions.
Chairwoman Kelly, members of the Committee, these claims are not true. These regulations are not minor or incremental changes. Their scope is nearly unlimited, and their implications are potentially enormous. These regulations exceed the OCC's statutory authority and disregard Congressional intent. The OCC adopted these regulations over the strong objections of CSBS, the National Governors Association, the National Conference of State Legislatures and all fifty state attorneys general. In adopting the regulations, the OCC ignored your own request for extra time to consider their implications. Instead, the OCC issued a set of regulations that may affect millions of consumers across the country without a public hearing and without meaningful consultation with the parties these regulations would affect.”