The United States Bankruptcy Panel of the First Circuit held that the Home Owner's Loan Act ("HOLA"), 12 U.S.C. § 1461 et seq. preempted certain Massachusetts statutory claims in the recent case Frykberg v. JPMorgan Chase Bank, N.A. (In re Frykberg), No. 12-050, 2013 WL 1704701 (B.A.P. 1st Cir. Apr. 18, 2013). There, the debtor filed an adversary complaint against JP Morgan Chase Bank, N.A. ("Chase") alleging claims under the Massachusetts Consumer Credit Cost Disclosure Act, Mass. Gen. Laws ch. 140D, § 8, and the Massachusetts Predatory Home Loan Practices Act, Mass. Gen. Laws ...
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