US President Donald Trump issued an executive order (EO) on February 3 that directs the secretary of the US Department of the Treasury and the heads of the major federal financial regulatory agencies to review “existing laws, treaties, regulations, guidance, reporting and recordkeeping requirements, and other government policies” for their consistency with a series of newly created “Core Principles” for the oversight and regulation of the financial sector, and to report back with their findings within 120 days.

Although not mentioned by name, the EO is aimed squarely at the Dodd-Frank Wall Street Accountability and Consumer Reform Act (Dodd-Frank Act)—as the president’s remarks at the signing event made clear.

As the incoming administration of President-elect Donald J. Trump prepares to roll back federal regulations impacting a wide variety of industries, the battleground will not just be in Washington, DC—it may emerge in the states.

During the Obama administration, state attorneys general—mostly Republican—have used their litigation authority to challenge federal regulations and executive orders that were designed to implement what could not be enacted in the US Congress. With the goal of stopping what they describe as federal government overreach, these attorneys general challenged the Affordable Care Act (Obamacare), Environmental Protection Agency (EPA) clean power rules, Obama’s executive order on immigration, and climate change regulations, among many other federal regulatory activities. In fact, just this week, 18 states filed a lawsuit challenging federal environmental regulations, specifically “overreaching new federal rules that broadly expand the definition of ‘critical’ habitat for endangered and threatened species.”