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National Bank Act

Cantero v. Bank of America

Issues

Does requiring a national bank to pay interest on escrow accounts attached to its mortgages under New York’s minimum interest-on-escrow law unconstitutionally infringe on the bank’s exercise of its federal power under the National Bank Act?

This case asks the Supreme Court to consider to what extent nationally-chartered banks should be shielded from state banking regulations on mortgage escrow accounts. Alex Cantero argues that the Second Circuit’s standard for preemption based on control is improper, and that the Court must evaluate the actual impact the interest-on-escrow law has on bank operations. Bank of America maintains that the state law is preempted because it both impermissibly exerts control over bank operations and also significantly hinders national banks’ exercise of their federally-granted powers. This case has significant implications not only for mortgage escrow accounts but also for states’ capacity to regulate other practices and products of federally-chartered banks.

Questions as Framed for the Court by the Parties

Whether the National Bank Act preempts the application of state escrow-interest laws to national banks.

The core banking powers of federally chartered banks such as the power to lend come from the National Bank Act (“NBA”). Brief for Respondent, Bank of America at 1. Under the NBA, chartering, regulation, and supervision of national banks are overseen by the Office of Comptroller of the Currency (“OCC”).

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Cuomo v. Clearing House Association, L.L.C.

Issues

Whether the Office of the Comptroller of the Currency's regulation 12 C.F.R. § 7.4000, which interprets 12 U.S.C. §484(a) of the National Bank Act to preempt state enforcement of state laws against national banks even when the state laws are not substantively preempted, is entitled to deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984), and/or whether the regulation is invalid because of the construction of the National Bank Act, as announced in First National Bank in St. Louis v. Missouri, 263 U.S. 640 (1924).

 

Suspecting racially discriminatory lending practices, the Attorney General of New York State sent letters of inquiry to numerous national banks requesting information about their lending practices and warning them of the potential illegality of their acts. The Office of the Controller of the Currency ("OCC") and the Clearing House Association L.C.C., which consists of several national banks, maintained that the National Bank Act's "visitorial powers" provisions, interpreted by the OCC in 12 C.F.R. § 7.4000, bar states from enforcing state laws against national banks. The Attorney General argues that the OCC's interpretation of § 7.4000 violates the Administrative Procedures Act, and that the National Bank Act's "visitorial powers" provisions do not interfere with state enforcement of their generally applicable laws. The decision in this case may affect lending practices and the balance of power between the federal government and state governments.

Questions as Framed for the Court by the Parties

12 U.S.C. § 484(a), a provision of the National Bank Act, prohibits the exercise of "visitorial powers" as to national banks, except where those powers are authorized by federal law, vested in the courts of justice, or exercised by Congress or a House or committee thereof. The Office of the Comptroller of the Currency has issued a regulation (12 C.F.R. § 7.4000) interpreting § 484(a) to preempt state enforcement of state laws against national banks, even when the state laws are not substantively preempted.

The questions presented are:

1. Whether 12 C.F.R. § 7.4000 is entitled to judicial deference under Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837 (1984).

2. Whether 12 C.F.R. § 7.4000 is invalid because it is inconsistent with the authoritative construction of the National Bank Act by this Court in First National Bank in St. Louis v. Missouri, 263 U.S. 640 (1924).

In 2005, Eliot Spitzer, in his official capacity as the New York State Attorney General, began investigating several national banks and their residential real estate lending practices for evidence of racial discrimination. See Clearing House Ass'n L.L.C. v.

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