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Dreher Tomkies LLP
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2750 Huntington Center
41 South High Street
Columbus, Ohio 43215
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FIRST DEPUTY COMPTROLLER AND CHIEF COUNSEL OF THE OCC SPEAKS ON THE IMPORTANCE OF FEDERAL PREEMPTION AND EXCLUSIVE VISITORIAL AUTHORITY

Julie L. Williams, First Senior Deputy Comptroller and Chief Counsel, Office of the Comptroller of the Currency, speaking to the OCC Alumni Association on May 14, 2003, stated that the uniformity of powers and operating standards that result from federal preemption coupled with the OCC's exclusive visitorial authority are defining characteristics of the national bank charter. In her remarks she stated that the OCC consistently has viewed the powers of the national bank charter as fundamentally evolutionary, capable of developing and adjusting as needed to support the changing financial and economic needs of the Nation and bank customers of all types. Apparently responding to criticism of the OCC proposed amendments to the rule on visitorial powers, Julie Williams stated that differences in national and state bank powers and in supervision and regulation of national and state banks are not inconsistent with the dual banking system, but rather are the defining characteristics of it. These remarks would indicate that the OCC continues to stand behind its proposed amendments to the rule on visitorial powers.

Michael Tomkies and Elizabeth Anstaett