This written testimony was presented on April 26, 2007, at a hearing on "Credit Card Practices: Current Consumer and Regulatory Issues," before the Subcommittee on Financial Institutions and Consumer Credit of the U.S. House of Representatives Committee on Financial Services. The testimony...

This comment letter responds to a proposed rule issued by the Office of the Comptroller of the Currency (OCC), which would “codify” an alleged federal common-law “principle” known as “valid-when-made.” The proposed rule would amend two of the OCC's regulations – 12 C.F.R. 7.4001...

This comment letter was submitted to the U.S. Treasury Department in connection with that Department's review of proposals for changes in the regulatory structure for financial institutions. The comment letter presents the following policy recommendations: (1) the thrift charter should be...

This policy brief examines several failures by the Office of the Comptroller of the Currency (OCC) to comply with the Dodd-Frank Act and other legal authorities governing the scope of preemption for national banks and federal savings associations. The policy brief argues that the OCC should...

This letter responds to the U.S. Treasury Department’s request for public comments on President Biden’s Executive Order No. 14067, “Ensuring Responsible Development of Digital Assets” (Mar. 9, 2022). This letter contends that (1) digital stablecoins currently pose significant risks to...