Letter to DOJ and NEC on the RFI Regarding State Laws

Dear Sir or Madam:

The American Bankers Association (ABA) appreciates the opportunity to respond to the Department of Justice (DOJ) and the National Economic Council (NEC) request for comments on information regarding State laws that adversely impact interstate commerce and/or business activities in other States. ABA firmly supports the goal of optimizing the regulatory environment and strengthening the American economy. To improve markets nationwide, ABA encourages the DOJ and the NEC to coordinate with the Office of the Comptroller of the Currency (OCC) to ensure that it continues to uphold a strong national bank preemption standard.

As noted by two former comptrollers of the currency, "our market-driven system provides maximum choice to consumers and businesses – including the choice for businesses like banks to operate under uniform national rules that minimize the cost, disruption, and confusion of a patchwork of local rules. The freedom to choose a single set of national standards yields efficiencies that benefit American consumers and businesses, both economically and operationally."

Under America's dual banking system, banks of all sizes freely determine whether to pursue a state charter or a national charter based on how they want to operate and innovate. Competition among state-chartered and national banks is invaluable to the world's most important financial system and economy as it continually spurs innovation and expands Americans' and American businesses' access to high-quality bank products and services.

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