On June 27, 2011, Civil Justice submitted to the Office of the Comptroller of the Currency (OCC) its comments regarding the OCC’s proposed regulatory amendments in response to the Dodd-Frank Wall Street Reform and Consumer Protection Act.  The Act was created to address serious problems with how consumers are protected from fraudulent or otherwise unethical behavior on the part of lenders, including mortgage companies.  Chief among these problems is the OCC’s 2004 regulation implementing the National Bank Act, which prevented a great number of state laws that protected consumers from abusive lending practices from being enforced against national banks.  This preemption of state law enabled national banks to engage in predatory and reckless lending practices and played a direct and significant role in causing the current financial crisis.      Unfortunately, the proposed regulations do not solve this problem, but rather amount to more of the same.  For example, while the Act specifically restricts the OCC’s...