A California Court of Appeal might have been humming the Fleetwood Mac song when it told the Ninth Circuit “no” on preemption. A California statute (Civ. Code § 1748.9) requires credit card issuers who offer “convenience checks” to make certain disclosures that differ from what the OCC regulations require. In Rose v. Chase, 513 F.3d 1032 (9th Cir. 2008), the Ninth Circuit found Section 1748.9 preempted. But on May 12, a state appellate court in Parks v. MBNA, 2010 Cal. App. LEXIS 671 (May 12, 2010) begged to differ. So, national banks either have to make the statemandated disclosures or not—depending on whether a future plaintiff sues them in state or federal court. Go figure.