A New York appellate court held HOLA and OTS regulations do not preempt claims brought by the NY AG against appraisal management companies hired by Washington Mutual, alleging those companies permitted Washington Mutual to select appraisers who would improperly inflate a property’s loan value to a targeted loan amount. People v. First American Corp., 902 N.Y.S.2d 521 (App. Div. 2010). The court rejected defendants’ argument that HOLA or FIRREA occupy the field of appraisal practices, that appraisal services are one of the areas of state law expressly preempted by OTS regulation 12 C.F.R. § 560, and that defendants’ actions were protected because they were acting as a federal thrift’s agent engaging in an authorized bank activity.