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Enforcement ActionLow RiskMultistate

Oregon AG Sues to Block OCC Rule Invalidating State Escrow Interest Laws

Office of the Comptroller of the CurrencyAugust 11, 2026Oregon Attorney General

Summary

Oregon Attorney General Dan Rayfield co-led a coalition of 10 states in a federal lawsuit against the Office of the Comptroller of the Currency (OCC) to block a rule that invalidates state laws requiring mortgage lenders to pay interest on escrow accounts. The lawsuit argues the OCC's rule oversteps federal authority, gives national banks a competitive advantage over state-chartered banks, and takes money away from homeowners.

Remedy

The states seek a court order wiping the OCC's rule off the books, restoring Oregon's interest-on-escrow law, and leveling the playing field between lenders and borrowers.

Injunction

Contract Impact

In-house legal teams at mortgage lenders and servicers should review their mortgage loan agreements and servicing contracts to ensure compliance with state escrow interest laws. The OCC's rule sought to exempt national banks from these requirements, but this lawsuit challenges that rule, so companies should monitor developments and ensure their contracts do not rely on the invalidated rule. Additionally, contracts with third-party servicers should include provisions requiring compliance with applicable state laws regarding escrow interest.

Contract Search Terms

escrow accountinterest on escrowmortgage escrowOCC compliancestate escrow interest lawmortgage servicing agreementescrow interest sharing

Laws Cited

OCC ruleOregon interest-on-escrow law

Violation Types

Entity Details

Entity

Office of the Comptroller of the Currency

Industry

Financial Services

Multistate Coalition

New York Attorney General Letitia JamesCalifornia Attorney GeneralConnecticut Attorney GeneralMaine Attorney GeneralMaryland Attorney GeneralMassachusetts Attorney GeneralMinnesota Attorney GeneralRhode Island Attorney GeneralVermont Attorney General

Official Sources

Source Evidence

Entity Name
"Office of the Comptroller of the Currency (OCC)"
Laws Cited
"Oregon law that requires mortgage lenders to pay interest on the money they require borrowers to deposit into escrow accounts"
Laws Cited
"state laws – including Oregon’s – requiring lenders to share the money they earn on borrowers’ escrowed funds"
Violation Types
"The case challenges a decision by a little-known but powerful federal agency, the Office of the Comptroller of the Currency (OCC), to invalidate an Oregon law"

Related Enforcement Actions

NY

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Nine state attorneys general, led by New York AG Letitia James, sued the U.S. Office of the Comptroller of the Currency (OCC) to stop two rules that preempt state laws requiring banks to pay interest on escrow accounts. The coalition argues the rules exceed OCC's authority under Dodd-Frank and the Administrative Procedure Act. The suit seeks a court order declaring the rules illegal and preventing their implementation.

CT

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Attorney General William Tong and a coalition of 10 attorneys general filed a lawsuit challenging a new OCC rule that preempts state laws requiring national banks to pay interest on homeowners' mortgage escrow accounts. The lawsuit argues the OCC ignored federal court decisions and bypassed safeguards, and seeks to block the rule.

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