OCC Issues Interim Final Rule and Order Preempting Illinois Interchange Fee Prohibition Act
Summary
The OCC issued two interim final actions on April 24, 2026: an interim final rule clarifying that national banks have longstanding Federal law powers to charge certain fees (regardless of whether set by the bank or a third party), and an interim final order expressly preempting the Illinois Interchange Fee Prohibition Act (IFPA) for national banks and Federal savings associations. The IFPA, which would have become effective July 1, 2026, is characterized by the OCC as creating a complex, potentially unworkable, and destabilizing standard for national banks, Federal savings associations, and the nation's payment card systems. Comments on both actions are due 30 days after Federal Register publication.
“The OCC's interim final order confirms that Federal law preempts the IFPA, expressly providing that national banks and Federal savings associations are neither subject to nor required to comply with this State law.”
National banks and Federal savings associations charging interchange or payment card fees should confirm their fee arrangements are documented under the OCC's preemption order — the Illinois IFPA does not apply to OCC-regulated institutions regardless of the July 1, 2026 state effective date. Institutions with cross-state payment card operations should monitor whether other states enact similar standards, as the OCC noted such effects could be exacerbated if other jurisdictions impose conflicting rules.
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What changed
The OCC issued two interim final actions on April 24, 2026: an interim final rule that clarifies the preexisting Federal law powers of national banks to charge certain fees, and an interim final order that expressly preempts the Illinois Interchange Fee Prohibition Act (IFPA) as applied to national banks and Federal savings associations. The IFPA would have taken effect July 1, 2026.
National banks and Federal savings associations are neither subject to nor required to comply with the IFPA under this order. Banks charging interchange or similar payment card fees should note that the OCC's actions affirm Federal preemption of state-level fee regulation in this area, and that the OCC characterized the Illinois law as potentially destabilizing to payment card systems. Comments on both documents are due 30 days after Federal Register publication.
Archived snapshot
Apr 25, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
News Release 2026-32 | April 24, 2026
OCC Issues Two Interim Final Actions Clarifying Bank Powers under Federal Law and the Preemption of a Related State Law
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WASHINGTON—The Office of the Comptroller of the Currency (OCC) today announced an interim final rule and interim final order related to activities of national banks and Federal savings associations. The interim final rule clarifies the longstanding powers under Federal law for national banks to charge certain fees, regardless of whether those fees are set by the bank or a third party.
These preexisting powers under Federal law have recently come into question relative to the Illinois Interchange Fee Prohibition Act (IFPA). The IFPA becomes effective on July 1, 2026, and would create a complex, potentially unworkable, and destabilizing standard for national banks, Federal savings associations, and the nation’s payment card systems. Further, such effects could be exacerbated to the extent other states impose similarly unworkable or conflicting standards.
The OCC’s interim final order confirms that Federal law preempts the IFPA, expressly providing that national banks and Federal savings associations are neither subject to nor required to comply with this State law. These two OCC actions will help prevent the imminent negative effects of the State law’s application to OCC-regulated banks. They do not affect and are not in conflict with the applicability of any other Federal laws that do or may in the future apply to banks regarding payment card activities. Indeed, by appropriately applying preemption to the IFPA, it affirms the ability of the Federal government, including Congress, to set consistent standards governing payment card activities of national banks and Federal savings associations, including as to interchange fees.
Comments on the interim final rule and interim final order are due 30 days after publication in the Federal Register.
Related Links
- Interim Final Rule: National Bank Non-Interest Charges and Fees (PDF)
- Interim Final Order: Order Preempting the Illinois Interchange Fee Prohibition Act (PDF)
Media Contact
Stephanie Collins
(202) 649-6870
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