Consumer and civil rights groups are up in arms over the Office of the Comptroller of the Currency’s recent interpretation of preemption under the Dodd-Frank Act, which would allow the OCC to generally retain its existing preemption regulations. The uproar stemmed from a letter the OCC sent to certain members of Congress on May 12 lay-ing out the agency’s views of its preemption powers under the new preemption provisions of Title X of the Dodd-Frank Act. Those views have been embodied in a proposed OCC rulemaking implementing several DFA provisions, including...