In this first half of a two-part article, the author reviews the complex structures through which federal and state consumerprotection laws are enacted and enforced with respect to commercial banks. Problems arisefrom the multiolicity of law-making bodies, the dual banking system, unclear preemption standards, and expandingfederal domination of the consumer creditfleld The secondpart of the article, which will appear in the next issue of this Review, analyzes the actual enforcement activities of the federal and state banking agencies. It concludes with a series of recommendationsfor improving the combined federal-state consumer protection programs affecting commercial banks.
Ralph J. Rohner, Problems of Federalism in the Regulation of Consumer Financial Services Offered by Commercial Banks, Part I, 29 CATH. U. L. REV. 1 (1979).