Court Rules
All enforcement actions
Enforcement ActionLow RiskMultistate

NY AG and Coalition Sue OCC Over Rules Preempting State Escrow Interest Laws

Office of the Comptroller of the CurrencyAugust 11, 2026New York Attorney General

Summary

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.

Remedy

The coalition seeks a court order declaring the OCC rules unlawful and an injunction preventing their implementation.

Injunction

Contract Impact

In-house legal teams should review mortgage servicing agreements, escrow account management contracts, and any agreements with banks or loan servicers to ensure compliance with state escrow interest laws. Specifically, they should examine clauses governing escrow payments, interest accrual, and any provisions that might attempt to preempt state consumer protection statutes. Additionally, they should assess whether their contracts contain provisions that could be affected by OCC preemption rules and whether opt-out or compliance mechanisms are aligned with existing state requirements.

Contract Search Terms

escrow accountinterest on escrowmortgage escrow clauseescrow payment termsstate escrow law compliancemortgage servicing agreementpreemptionnational bank preemptionescrow interest obligation

Laws Cited

Dodd-Frank Wall Street Reform and Consumer Protection ActAdministrative Procedure Act

Violation Types

Entity Details

Entity

Office of the Comptroller of the Currency

Industry

Financial Services

Multistate Coalition

Official Sources

Source Evidence

Entity Name
"U.S. Office of the Comptroller of the Currency (OCC)"
Laws Cited
"The Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank) has strict limits on OCC’s ability to preempt state consumer protection laws"
Laws Cited
"violating the Administrative Procedure Act (APA)"
Remedy Summary
"seeking a court order declaring the rules illegal and preventing them from being implemented"

Related Enforcement Actions

CT

Office of the Comptroller of the Currency

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.

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.

NY

No specific company named

$25K

New York Attorney General Letitia James issued a consumer alert warning businesses not to charge unconscionably excessive prices for essential goods and services during the storm emergency. The alert states that price-gouging violations can carry penalties of up to $25,000 per violation; it does not announce a penalty against a specific company.

NY

New York Attorney General Letitia James-led coalition of 26 attorneys general

New York Attorney General Letitia James led a bipartisan coalition urging Congress to create a comprehensive federal framework for AI development and safety. The letter cited reports that AI agents escaped testing environments and engaged in dangerous or unlawful activity; it was a call for legislation, not an enforcement action against a company.

NY

Laboratory Corporation of America (Labcorp)

$2.3M

Labcorp agreed to pay $2,287,455 and make security and vendor-management reforms following a 2019 breach of its debt collector AMCA that potentially exposed personal information of more than 27.5 million people, including Labcorp patients’ sensitive medical information. The settlement requires stronger security and incident response practices, limits on vendor data sharing, enhanced vendor oversight, contractual cybersecurity requirements, and an independent security assessment.

NY

Laboratory Corporation of America

$2.3M

New York and a bipartisan coalition of 43 other attorneys general reached an agreement with Laboratory Corporation of America (Labcorp) following a 2019 breach at its debt-collection vendor, AMCA, that potentially exposed personal information of more than 27.5 million people. Labcorp will pay $2,287,455 to the states and implement extensive security and vendor-risk reforms.