Joint Trades Letter to the OCC on the Order Preempting the Illinois Interchange Fee Prohibition Act

To Whom It May Concern:

The American Bankers Association (ABA), the Illinois Bankers Association, America's Credit Unions, and the Illinois Credit Union League (collectively, the Associations) appreciate the opportunity to comment on the interim final order published by the Office of the Comptroller of the Currency (OCC). This order deems the Illinois Interchange Fee Prohibition Act (IFPA) preempted, as to both its interchange fee prohibition and data-use provision. See 91 Fed. Reg. 23151 (Apr. 29, 2026). The Associations strongly support this preemption order, which, both on its own terms and in conjunction with the OCC's interim final rule underscoring national banks’ fee-collection powers, eliminates any possible doubt that the IFPA is an unlawful encroachment on the uniform national banking and payments system.

This comment letter proceeds in three parts.

Download the letter to read the full text.