On July 9th, the Eighth Circuit held that a national banking association chartered by the OCC but not registered to do business with the Arkansas Secretary of State or the Arkansas Bank Department could use the non-judicial foreclosure procedure provided by the Arkansas Statutory Foreclosure Act ("SFA"). An entity may be authorized to do business in Arkansas for SFA purposes under either state or federal law. Here, the National Bank Act provided such authorization. JP Morgan Chase Bank, N.A. v. Johnson.