Supporting, Informing & Connecting People in Foreclosure
National banks love making the argument that they don't have to register the trust with the state. However, they conveniently forget to tell the whole story. Pursuant to 12 USC § 92a they are exempted from state law. But they MUST first obtain a special permit from the Comptroller of the Currency (OCC) in order to be exempt.
The OCC Interpretive Letter #1106 gives more detail information. So the bank must show with evidence that it obtained a special permit from the OCC.