OCC: National Bank Non-Interest Charges and Fees; Preempting the Illinois Interchange Fee Prohibition Act (May 29, 2026)

FMI – The Food Industry Association welcomes this opportunity to comment on the Office of the Comptroller of the Currency’s (OCC) interim final rule on National Bank Non-Interest Charges and Fees, Docket ID OCC-2026-0430 (“IFR” or “rule”) and interim final order (“order”) Preempting the Illinois Interchange Fee Prohibition Act, Docket ID OCC-2026-0431. FMI strongly opposes the issuance of the IFR and order for several reasons. FMI believes both the IFR and order are anticompetitive, undermine President Trump’s endorsement of swipe fee reform and affordability agenda to lower costs for consumers and businesses, and were issued through a deeply flawed and legally deficient process that we believe will not withstand judicial scrutiny. We urge the OCC to rescind the IFR and order and reaffirm its previously held commitment to marketplace competition in the charging of bank fees.