Advocates of more aggressive enforcement of the fair lending law called this an important gap in the proposed new rules.
New York's lending laws include, among other provisions, a limit on prepayment penalties to the first year of the loan.
The proposed regulations came as the comptroller specifically exempted national banks from the predatory lending law in Georgia.
Efforts by states to enact predatory lending laws have been running into obstacles all year.
A principal obstacle has been restrictions by credit agencies on their ratings for pools of mortgages from the states with predatory lending laws.
One of his friends suggested he could make a nice living advising banks on how to comply with the lending laws.
The state predatory lending law is to go into effect in April.
It's a stance that banking lawyers argue extends beyond the scope of the fair lending laws.
"We are quite concerned about 'the death of a thousand cuts' for predatory lending laws across the country."
She said the bank complied with "fair lending laws" and ethical business practices.