On July 20th, the OCC issued a new final rule implementing several provisions of the Dodd-Frank Act, including changes to facilitate the transfer of functions from the Office of Thrift Supervision and revisions to the OCC's rules on preemption and visitorial powers. Among other things, the new final rules eliminate preemption for operating subsidiaries of national banks and operating subsidiaries of Federal savings associations; apply to federal thrifts the same conflict preemption standard that apply to national banks, and apply to Federal thrifts the visitorial powers standards applicable to national banks; and revise the OCC's visitorial powers rule to conform to the U.S. Supreme Court's decision recognizing the ability of state attorneys general to bring enforcement actions in court to enforce applicable laws against national banks as authorized by such laws. In response to public comments, the text of the preemption and visitorial powers amendments was revised to add language to clarify that federal savings associations will be subject to the same preemption standards that apply to national banks; clarify the definition of "visitorial powers" to include direct investigations of national banks, such as through requests for documents or testimony directed to the bank to ascertain the bank's compliance with law through mechanisms not otherwise authorized under the rule. OCC Press Release.