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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

California Attorney GeneralMaine Attorney GeneralMaryland Attorney GeneralMassachusetts Attorney GeneralMinnesota Attorney GeneralNew York Attorney GeneralOregon Attorney GeneralRhode Island Attorney GeneralVermont Attorney General

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

Perry Johnson & Associates, Inc.; Perry Johnson, Inc.; Perry Johnson & Associates Coding, Inc.; Perry Johnson & Associates Radiology, Inc.; and Medical Transcription and Coding, Inc.

$10.0M

A March 2023 breach exposed personal and protected health information belonging to more than 13.3 million people after hackers accessed the companies’ systems, including unencrypted files, and security alerts were not properly configured. The companies agreed to pay at least $300,000 in penalties, with up to $9.7 million more due if they fail to comply, and to implement extensive security, incident-response, and data-handling reforms.

CT

United States Department of Justice

Connecticut Attorney General William Tong and a 23-state coalition obtained a court ruling declaring unlawful federal immigration-enforcement conditions placed on Congressionally authorized public safety grants. The court permanently enjoined the federal government from implementing or enforcing those conditions; the release does not describe a privacy violation or monetary penalty.

CT

Bipartisan coalition of 45 attorneys general

Connecticut Attorney General William Tong co-led a bipartisan coalition of 45 attorneys general urging Congress to pass the Kids Online Safety Act. This was a legislative advocacy effort, not a new enforcement action; the release discusses prior investigations into platforms’ effects on children and a separate Meta settlement.

CT

U.S. Census Bureau

Connecticut Attorney General William Tong joined a coalition of 24 attorneys general and two governors in opposing proposed changes to the 2030 Census. The coalition argued the proposal would exclude people from the count, remove demographic questions, and replace the usual-residence standard; this was a comment-letter action, not a penalty or enforcement order.