Regulatory Alerts2026-04-24
National Bank Non-Interest Charges and Fees
The Office of the Comptroller of the Currency issued an interim final rule amending 12 CFR section 7.4002 to clarify that national banks possess the broad authority to assess, collect, and impose non-interest charges and fees, including interchange fees from credit and debit card operations. The rule explicitly permits national banks to charge these fees even when the amounts are established by or negotiated with third-party card networks, resolving recent judicial ambiguity regarding third-party fee-setting. By redefining charge, removing the restrictive term customer, and codifying interchange fees as a nonexclusive example, the amendment ensures national banks retain full discretionary control over payment card pricing and fee structures.