OCC preempts Illinois Interchange Fee Act with interim rule and order

9 articles · Updated · occ.treas.gov · Apr 24

The OCC's actions clarify that national banks and Federal savings associations are not subject to the Illinois Interchange Fee Prohibition Act, which was set to take effect July 1, 2026.
The interim final rule affirms longstanding federal authority over bank fee practices, preventing potentially destabilizing effects on payment card systems if conflicting state laws like the IFPA were enforced.
These measures reinforce the federal government's role in setting consistent standards for payment card activities, while allowing for future federal laws to apply to banks regarding interchange fees.

How might the OCC’s preemption of the Illinois law reshape the balance of power between state and federal regulation of payment systems?

How does the OCC’s stance align with international trends in interchange fee regulation and consumer protection?

What could be the long-term impact on consumer rewards and card fees if similar state laws are introduced elsewhere?

Will merchants find new ways to reduce interchange costs, or will these federal actions limit their options nationwide?

How might ongoing litigation and potential appeals affect the implementation of the OCC's interim rule and order?