
occ_jun2011_OCC-2011-0006_doddfrankpreemption_0.pdfIn this comment letter submitted to the OCC regarding the implementation of te Dodd-Frank, Woodstock Institute urges the agency to repeal its existing preemption orders, make public its process for the preemption of existing state consumer protections and to apply the reformulated preemption standard with the intent of expanding, rather than reducing, consumer protections.