The state of Colorado filed a response to our Petition for Rehearing en Banc in the10th Circuit Court of Appeals, where the majority of a three judge panel overturned a decision holding that Colorado couldn’t control out of state banks by opting out of the uniform federal interstate banking framework set by Congress and its Depository Institutions Deregulation and Monetary Control Act (DIDMCA).
In our suit, AFSA and other national trade associations challenged Colorado’s misinterpretation of DIDMCA, which if allowed to stand would undermine the parity between state- and federal-chartered banks, upending the dual banking system.
As AFSA President and CEO Celia Winslow noted, “DIDMCA was intended to level the playing field between state and nationally chartered banks. Now, Colorado is attempting to regulate not just its state-chartered banks, but also banks chartered in other states. This is not what DIDMCA was intended to do and is certainly not in the best interests of consumers in Colorado or anywhere else.”
AFSA and our co-plaintiffs argue that if Colorado’s opt-out effort stands–and other states were to follow—the interest rate and rules governing a single contract or transaction would be subject nonsensically to conflicting state laws including the rate in a state where a consumer lives, the rate where a bank is chartered, and even potentially where a purchase is made. AFSA has long argued—and research confirms—that fewer credit options and restrictions on competition limit access to credit, especially for low-income Americans and reduce credit options for all consumers.
AFSA will continue to support the dual banking system and rights of state-chartered bank to operate on a level playing field with national banks.
Read the joint trade release here.
Read our Petition for Rehearing en Banc here
Read all AFSA resources on DIDMCA here
On Colorado’s Actions to Limit Interstate Banking under DIDMCA
Jan 22, 2026
The state of Colorado filed a response to our Petition for Rehearing en Banc in the10th Circuit Court of Appeals, where the majority of a three judge panel overturned a decision holding that Colorado couldn’t control out of state banks by opting… Read the rest
THIS THURSDAY | AFSA Webinar | 2026 Consumer Lending Predictions: The AI Power Shift That Will Redefine the Industry—Whether We’re Ready or Not
Jan 20, 2026
2026 Consumer Lending Predictions: The AI Power Shift That Will Redefine the Industry—Whether We’re Ready or Not
Thursday, January 22, 2026 | 2:00 p.m. ET
The consumer and auto finance industry is standing on the edge of its most radical transformation… Read the rest
Extra Credit Podcast | AI in Financial Services w/ Sigmoid Analytics
Jan 15, 2026
Happy New Year! The AFSA Extra Credit Podcast is back with fresh perspectives, best practices and great conversations with consumer credit industry leaders
In this episode of the AFSA Extra Credit Podcast, Dan Bucherer chats with Ravi Bajagur… Read the rest
AFSA Webinar | 2026 Consumer Lending Predictions: The AI Power Shift That Will Redefine the Industry—Whether We’re Ready or Not
Jan 15, 2026
2026 Consumer Lending Predictions: The AI Power Shift That Will Redefine the Industry—Whether We’re Ready or Not
Thursday, January 22, 2026 | 2:00 p.m. ET
The consumer and auto finance industry is standing on the edge of its most radical transformation… Read the rest
The New Fraud Playbook | 2026 Vehicle Finance Conference & Expo
Jan 14, 2026
Vehicle finance fraud is escalating, with AI serving as both weapon and defense. This session examines the growing fraud trends, from synthetic identities to fake documentation and bust outs, while exploring how lenders can deploy tools… Read the rest
CEO Roundtable | 2026 Vehicle Finance Conference & Expo
Jan 13, 2026
Join us for a fast-paced discussion where these industry leaders pull back the curtain on what they are seeing in today’s marketplace … and tomorrow’s.
Discover the strategies they’re using to navigate disruption in the market… Read the rest
On Price Controls and Affordability
Jan 10, 2026
There are few trade associations with a track record of helping American consumers at every level of the financial spectrum through challenging economic times than the American Financial Services Association. For more than 100 years AFSA… Read the rest
Risk, Resolve, and Resilience. A Blueprint for Breakthrough Teams and Results.
Jan 08, 2026
Join us on Monday, February 2nd to hear from our 2026 Vehicle Finance Conference & Expo keynote speaker, Alison Levine, a preeminent business leadership expert, Alison Levine, mountaineer and polar explorer, faculty member at the Thayer… Read the rest
January White Paper: Review and Preview
Jan 08, 2026
AFSA’s State Government Affairs team released its latest white paper, which provides a 2026 State Legislative Session preview and 2025 year-in review.
The 2026 State Legislative agenda is focused on such emerging issues as Artificial… Read the rest
Student Loan Fallout
Jan 08, 2026
The Trump administration has reinstated wage garnishment for federal student loan borrowers in default following the expiration of pandemic-era repayment, reporting, and collections moratoria. Delinquency rates have skyrocketed… Read the rest