The Eleventh Circuit has joined the Fifth Circuit and several district courts in holding a state par value statute was preempted to the extent that it prohibited national banks from charging check-cashing fees. Baptista v. JP Morgan Chase Bank, N.A., 2011 U.S. App. LEXIS 9568 (11th Cir. May 11, 2011). Although Dodd-Frank doesn’t become effective until July 2011, the Court took the opportunity to opine that the Act codifies a conflict preemption standard, which the Court articulated as “whether there is a significant conflict between the state and federal statutes.” Id. at *4. The OCC cited this interpretation in support of its view that the “prevents or significantly interfere” language is merely the beginning of the Dodd-Frank preemption analysis.