Regulatory Alerts2026-04-24
Preemption of Illinois Interchange Fee Prohibition Act: Interim Final Order
The Office of the Comptroller of the Currency issued an interim final order preempting the Illinois Interchange Fee Prohibition Act, which prohibits national banks and Federal savings associations from charging interchange fees on tax and gratuity amounts and restricts their use of payment card transaction data. The order determines that the state law significantly interferes with these institutions’ statutory powers to process payments and charge fees, thereby eliminating compliance costs and operational uncertainty under the National Bank Act and Home Owners’ Loan Act. Effective June 30, 2026, the order invites public comments by May 29, 2026 to inform a forthcoming final determination.
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