The OCC has informed us that they do not view the Illinois law and rules on senior financial exploitation training as applying to national banks. They do not mind if national banks voluntarily comply, but they would object to any attempts at state enforcement of the law against a national bank. Their position is based on the OCC’s exclusive visitorial powers. If anyone in your law or compliance department remains concerned about compliance, they should contact Coreen Arnold, the regional counsel for the OCC in its Chicago office, who provided this information to us.
Are national banks required to comply with the Illinois elder financial exploitation training requirements?
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