Respondent Chain Bridge Bank, N.A., wired over $456 million out of petitioner Blue Flame Medical LLC's account without authorization. The question is whether petitioner's state-law claims challenging that conduct are preempted by the U.S. Federal Reserve Bank's Regulation J, Subpart B, which governs cash-equivalent interbank payment orders over the Fedwire Funds Transfer System, commonly known as "wire transfers."

The Fourth Circuit recognized that once a bank accepts a wire transfer and credits the funds to its customer's account, that money belongs to the customer. That is the essential premise of a wire—it is immediate and irrevocable. Any dispute about the funds must be settled another way, for example, through litigation. Yet the court held that when a bank takes money out of its customer's account without authorization and gives it back to the sender, there is no remedy. Regulation J failed to address this circumstance, the court held. And based on circuit precedent interpreting commentary—not Regulation J's provisions or the enabling statute—the Fourth Circuit gave implied field-preemptive effect to the regulation, precluding any state law that might fill the gap. That understanding has been adopted in several other circuits as well. The question presented is:

Does the Federal Reserve's Regulation J impliedly preempt the field regarding the conduct of parties to a Fedwire Funds Service wire transfer, based on commentary to the regulation and Article 4A of the Uniform Commercial Code, as the First, Fourth, Ninth, and Eleventh Circuits have held?

Whether petitioner's state-law claims challenging the unauthorized wire transfer of over $456 million from its account are preempted by the Federal Reserve's Regulation J