In a clash of competing sovereigns’ interests, the United States Court of Appeals for the Second Circuit upheld the authority of the New York Department of Financial Services (DFS) to regulate online payday loans made by Indian tribal lenders (the tribal lenders) to New York borrowers.  The Second Circuit’s decision in the Otoe-Missouria case affirmed the lower court’s denial of a preliminary injunction sought by the tribal lenders to prevent the DFS from interfering with the tribes’ consumer lending business by barring these loans and pressuring banks and the National Association of Clearing House Associations (NACHA) to cease doing business with  MORE >