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Enforcement ActionLow RiskMultistate

Attorney General William Tong Sues to Block OCC Rule on Mortgage Escrow Interest

Office of the Comptroller of the CurrencyAugust 11, 2026Connecticut Attorney General

Summary

Attorney General William Tong and a coalition of 10 attorneys general filed a lawsuit challenging a new OCC rule that preempts state laws requiring national banks to pay interest on homeowners' mortgage escrow accounts. The lawsuit argues the OCC ignored federal court decisions and bypassed safeguards, and seeks to block the rule.

Remedy

The coalition seeks to block the OCC rule and preserve state authority to require interest payments on mortgage escrow accounts.

Injunction

Contract Impact

In-house counsel for financial institutions should review mortgage servicing agreements and escrow account provisions to assess reliance on federal preemption of state interest-on-escrow requirements. They should also review vendor contracts with national banks for clauses related to regulatory compliance and changes in law, and consider whether state escrow interest laws apply to their operations. If the lawsuit succeeds, banks may need to implement systems to track and pay interest on escrow accounts, so contracts with loan servicers should allocate responsibility for such payments and compliance.

Contract Search Terms

escrow accountinterest on escrowmortgage servicingpreemption clausenational bankstate consumer protectionescrow interest paymentloan servicer agreementregulatory compliance clause

Violation Types

Entity Details

Entity

Office of the Comptroller of the Currency

Industry

Financial Services

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"filed a lawsuit today opposing a new rule issued by federal regulator of national banks, the Office of the Comptroller of the Currency (OCC), that would strip states of their authority to require national banks to pay interest on homeowners’ mortgage escrow accounts."
Is Multistate
"Joining Attorney General Tong in filing this lawsuit are the attorneys general of California, Maine, Maryland, Massachusetts, Minnesota, New York, Oregon, Rhode Island, and Vermont."
Remedy Types
"Attorney General William Tong and a coalition of 10 attorneys general filed a lawsuit today opposing a new rule"

Related Enforcement Actions

NY

Office of the Comptroller of the Currency

Nine state attorneys general, led by New York AG Letitia James, sued the U.S. Office of the Comptroller of the Currency (OCC) to stop two rules that preempt state laws requiring banks to pay interest on escrow accounts. The coalition argues the rules exceed OCC's authority under Dodd-Frank and the Administrative Procedure Act. The suit seeks a court order declaring the rules illegal and preventing their implementation.

OR

Office of the Comptroller of the Currency

Oregon Attorney General Dan Rayfield co-led a coalition of 10 states in a federal lawsuit against the Office of the Comptroller of the Currency (OCC) to block a rule that invalidates state laws requiring mortgage lenders to pay interest on escrow accounts. The lawsuit argues the OCC's rule oversteps federal authority, gives national banks a competitive advantage over state-chartered banks, and takes money away from homeowners.

CT

U.S. Department of Health and Human Services (HHS)

Connecticut Attorney General William Tong joined a coalition of 22 attorneys general and Pennsylvania’s governor in a letter urging HHS to keep federal vaccine recommendations grounded in scientific and medical evidence. The letter asks HHS to preserve the ACIP’s role and current vaccine recommendation categories; it is a policy advocacy action, not a privacy enforcement action.

CT

Laboratory Corporation of America

$2.3M

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CT

AI industry

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CT

U.S. Department of the Interior

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