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FDIC Federal Register Citations

State of California - Office the Attorney General

May 18, 2005

Mr. Robert E. Feldman, Executive Secretary
Attn: Comments/Legal ESS, Room 3060
Federal Deposit Insurance Corporation
550 17th Street, NW.
Washington, DC 20429

 Re: Petition for Rulemaking to Preempt Certain State Laws
       70 FR 13413 (March 21, 2005)

Dear Mr. Feldman:

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.


Bill Lockyer
Attorney General

Last Updated 05/20/2005

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