The "biggest check first" policy is common among large U.S. banks. Banks argue that this is done to prevent a customer's most important transactions (such as a rent or mortgage check, or utility payment) from being returned unpaid, despite some such transactions being guaranteed. Consumers have attempted to litigate to prevent this practice, arguing that banks use "biggest check first" to manipulate the order of transactions to artificially trigger more overdraft fees to collect. Banks in the United States are mostly regulated by the Office of the Comptroller of the Currency, a Federal agency, which has formally approved of the practice; the practice has recently been challenged, however, under numerous individual state deceptive practice laws. In class action, U.S. Bank Corporation entered into a $55 million settlement agreement on January 16, 2014 over the practice of reordering transactions (highest-lowest) in posting debit card transactions to customer accounts and the alleged effect the posting order had on the number of overdraft fees charged to account holders.