In April, my colleague, Bloomberg Law Legal Analyst Erin Webb, surveyed Trump administration efforts to preempt states on climate change and immigration. The administration also has deregulatory goals in finance, and is using federal financial regulators to preempt state regulation.
OCC Has Banks Override States
The most preemption-prone financial regulator may be the Office of the Comptroller of Currency.
In May 2025, the Conference of State Bank Supervisors asked the OCC to rescind its rules determining when the National Bank Act preempts state banking laws for OCC-chartered banks. The OCC responded that it will “continue to vigorously support and defend ...