Joint Trades Letter to the OCC on National Bank Non-Interest Charges and Fees

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 rule published by the Office of the Comptroller of the Currency (OCC). This rulemaking amends the OCC’s regulation on national bank charges to make clear national banks’ broad authority to charge and receive fees in the course of banking, including interchange fees. See 91 Fed. Reg. 22989 (Apr. 29, 2026). The undersigned groups strongly support this amendment, which, both on its own terms and in conjunction with the OCC’s parallel order on preemption, eliminates any possible doubt that the Illinois Interchange Fee Prohibition Act (IFPA) is an unlawful encroachment on the uniform national banking and payments system.

This comment letter proceeds in four parts.

Download the letter to read the full text.