Are national banks guilty of conversion by assessing servicing fees to debtors whose accounts are subject to a garnishment order and extracting those fees from garnished funds before releasing the remaining funds to garnishors? An Ohio federal court won’t reach the question because the Sixth Circuit affirmed its decision finding the claim is expressly preempted by OCC regulations. Monroe Retail, Inc. v. RBS Citizens, N.A., 589 F.3d 274 (6th Cir. 2009). Deferring to an OCC opinion letter, the court found state law claims that would prevent national banks from balancing their accounts and collecting fees prior to remitting funds to garnishors would significantly interfere with the banks’ federal authority. A dissenting judge disagreed on grounds that laws of general applicability are not preempted.