In his Note, The OCC's Exclusive Visitorial Authority over National Banks AfterClearing House Ass'n v. Cuomo, Matt Nance examines the role of the Office of the Comptroller of the Currency (OCC)—an agency within the U.S. Department of the Treasury charged with regulating nationally chartered banks. 

The OCC has recently enjoyed a string of victories, as federal courts have struck down state legislation regarding check-cashing fees and bank licensing.  In 2007, the Second Circuit held in Clearing House Ass'n v. Cuomo, that although New York state fair-lending laws remain valid, only the OCC—not the New York attorney general—has authority to enforce those state laws against national banks.  This raises a question: When does the OCC have exclusive authority to enforce otherwise valid state laws?  Nance examines the history of the OCC and case law regarding the OCC's authority, arguing that both support the position that the OCC only has exclusive authority to enforce state consumer-protection laws that are specific to the business of banking.