This decision holds that a bank or other non-savings and loan that acquired a loan originated by a savings and loan before the Dodd-Frank Act, is entitled to assert the same Home Owners Loan Act field preemption of state law as the originating savings institution could have. To hold otherwise would impair an essential feature of how savings institutions worked from 1980 to 2009–selling their home loans into the secondary market. The OTS’s field preemption regulation preempts California’s interest-on-escrow statute, Civ. Code 2954.8. The regulation expressly preempted state statutes imposing requirements regarding escrow accounts, which section 2954.8 clearly does. Also, the state statute is more generally preempted because it has more than an incidental effect on a savings institution’s operations by making it more difficult or less lucrative for the savings institution to sell its loans into the secondary market. The FHLBB and OTS had also issued two opinion letters agreeing that interest-on-escrow statutes were preempted under HOLA.