I am writing to express my agreement with and join in the comments previously filed by the New York Attorney General on behalf of himself and the Attorneys General of the States of Connecticut, Illinois, Iowa, New Mexico, North Carolina and Vermont. I urge the FDIC to deny in its entirety the petition filed by the Financial Services Roundtable. That petition requests the FDIC to adopt rules that would effectively immunize state banks from complying with the laws of the states in which they conduct business.

The action sought by the Financial Services Roundtable is beyond the legal authority of the FDIC. Furthermore, adoption of such rules would be contrary to long-established principles of federalism and would have  a significant adverse effect on consumer protection. The expansion of preemption sought by the Financial Services Roundtable is in violation of law, precedent, and sound policy and should therefore be rejected.

Sincerely,

Bill Lockyer
Attorney General