(1996)

Dear Commissioners Bartlett and Hergenroeder:

You have requested our opinion whether the Commissioner of Financial Regulation may authorize State-chartered banks to sell insurance directly. Your question results from the fact that federal law grants national banks that authority, and state laws to the contrary are preempted. Barnett Bank v. Nelson, ___ U.S. ___, 116 S. Ct. 1103 (1996). See 81 Opinions of the AttorneyGeneral ___ (1996) [Opinion No. 96-032 (September 26, 1996)].

Our opinion is that the Commissioner of Financial Regulation may approve the application of State-chartered banks to…