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OCC preempts Illinois interchange-fee restrictions for national banks

National banks may treat Illinois interchange-fee limits as preempted

Financial Services Fintech & Payments
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OCC issued an interim final order concluding that federal law preempts the Illinois Interchange Fee Prohibition Act for national banks and federal savings associations, effective June 30, 2026.
Why it matters
The order removes the Illinois Act’s restrictions from national banks and federal savings associations for covered interchange-fee and payment-card data activities. Legal, payments and compliance teams must align Illinois card-transaction controls with the OCC preemption order while tracking the May 29 comment deadline.
Implications
  • — National bank legal and compliance teams must treat the Illinois Interchange Fee Prohibition Act as preempted for covered interchange-fee and payment-card data restrictions from June 30, 2026.
  • — Federal savings association payments teams must align Illinois card-transaction pricing and data-use controls with the OCC interim final order.
  • — Bank regulatory-affairs teams must submit any comments on the interim final order by May 29, 2026.
Who is affected
  • — National bank legal and compliance teams
  • — Federal savings association payments teams
  • — Bank regulatory-affairs teams handling OCC comments
What to watch
  • — Bulletin publication date: April 24, 2026
  • — Comment deadline: May 29, 2026
  • — Effective date: June 30, 2026
  • — Docket ID: OCC-2026-0431

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