2025 Regulatory Summit

Preliminary Injunction – Riegle Neal Preemption

• Statutory Framework – Riegle-Neal: Host state laws apply to branches of out-of-state state banks to the same extent as they apply to branches of out-of-state national banks. • Court’s View – Riegle-Neal likely preempts the IFPA for out-of-state state banks. – Plain text reflects Congress’s intent to ensure competitive parity between out-of state state banks and national banks. – Court relied on Eleventh Circuit’s decision in Pereira v. Regions Bank . • On the Merits – Illinois Attorney General emphasized the statute’s “branch” limitation.

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Broader Implications

• Could reshape the financial landscape beyond Illinois , with nationwide effects. • Creates regulatory fragmentation , driving up: – Compliance costs – Operational complexity – Legal uncertainty • Risks creating a patchwork of state rules, undermining uniform payment systems.

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