Avid readers will recall that in our last issue we discussed the Eleventh Circuit’s decision in Baptista v. JP Morgan Chase Bank, N.A., 2011 U.S. App. LEXIS 9568 (11th Cir. May 11, 2011), holding a state par value statute and common law claim based on the same theory were preempted by the National Bank Act and OCC regulations. However, a district court held that this ruling did not require reconsideration of its decision holding state law challenges to national bank’s payment posting practices were not preempted. In re Checking Account Overdraft Litigation, 2011 WL 2746171 (S.D. Fla. July 13, 2011). The court stuck with its conclusion that state laws must be in irreconcilable conflict with federal law, and the challenged state law must specifically target banking practices for preemption to apply.