OCC clarifies national banks’ authority over non-interest fees
National banks may charge non-interest and interchange fees under OCC’s clarified authority
Change
OCC issued an interim final rule clarifying national banks’ authority to charge non-interest fees, including interchange fees from credit and debit card activity, effective June 30, 2026.
Why it matters
The rule clarifies that national banks may assess, collect, impose, levy, receive, reserve, take or otherwise obtain non-interest charges and fees. Payments, legal and compliance teams must align fee authority, interchange-fee controls and third-party fee-setting arrangements with the amended 12 CFR 7.4002.
Implications
- — National bank legal and compliance teams must update non-interest fee policies to reflect OCC’s clarified authority under amended 12 CFR 7.4002.
- — Payments and card-operations teams at national banks must treat interchange fees from credit and debit card activity as covered non-interest charges and fees under the interim final rule.
- — National banks using third-party-set or third-party-consulted fee arrangements must review those arrangements against OCC’s clarified fee authority before the June 30, 2026 effective date.
Who is affected
- — National bank legal and compliance teams
- — Payments and card-operations teams at national banks
- — Community banks with national bank charters
- — Federal branches and agencies subject to OCC supervision
What to watch
- — Bulletin publication date: April 24, 2026
- — Effective date: June 30, 2026
- — Comments due 30 days after Federal Register publication
- — Amendment to 12 CFR 7.4002
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