Order Preempting the Illinois Interchange Fee Prohibition Act
Summary
The OCC published an order preempting the Illinois Interchange Fee Prohibition Act under federal preemption authority. The state statute, which would have prohibited merchants from paying interchange fees on credit card transactions, is now preempted and cannot be enforced. Financial institutions and card networks may continue existing interchange fee arrangements without compliance obligations under Illinois law.
“Order Preempting the Illinois Interchange Fee Prohibition Act”
Nationally chartered banks and card networks operating in Illinois should confirm their interchange fee structures are governed by federal preemption rather than the now-blocked Illinois statute. Merchants who anticipated reduced swipe fees under Illinois law will need to continue operating under existing card network fee arrangements.
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What changed
The OCC issued an order preempting the Illinois Interchange Fee Prohibition Act, invoking federal preemption authority over state regulation of nationally chartered banks and payment card networks. This unpublished notice, scheduled for official publication on April 29, 2026, formally blocks the Illinois statute from taking effect.
Affected parties include financial institutions, card networks (Visa, Mastercard, American Express), and Illinois merchants who would have benefited from the state's swipe fee restrictions. Banks operating nationally or with federal charters in Illinois should review their interchange fee arrangements and merchant agreements in light of this federal preemption, which supersedes the state-level prohibition.
Archived snapshot
Apr 28, 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.
Public Inspection :: Notice
Order Preempting the Illinois Interchange Fee Prohibition Act
An unpublished Notice
by the Comptroller of the Currency on 04/29/2026
- Document Details
- Sharing Public Inspection Document This document is unpublished. It is scheduled to be published on 04/29/2026.
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