Comment from Public Service Credit Union

Melane Conyers-Ausbrooks Secretary of the Board National Credit Union Administration 1775 Duke Street Alexandria, Virginia 22314-3428 Docket ID: NCUA-2026-1189 To Whom It May Concern, We’re writing to express our appreciation to the National Credit Union Administration (NCUA) for its interim final rule clarifying the longstanding authority under federal law for federal credit unions to charge non-interest fees, including interchange fees, regardless of whether those fees are set by the credit union or by a contract with a third party. That rule is consistent with the recent interim final rule issued by the OCC. We urge the NCUA to finalize this rule to provide continued certainty for federal credit unions and the members they serve. It is critical for the smooth operation of the nationwide card-based payment system that we are able to offer cards that work the same regardless of where the cardholder chooses to use them. As such, we strongly believe that federal preemption is necessary to ensure and preserve a national card-based payment system. Without it, the Illinois Interchange Fee Prohibition Act (IFPA) and similar state laws introduce a complex and potentially unworkable standard, imposing significant potential liability for non-compliance. These laws risk creating a fragmented payment network as states consider or enact differing requirements. Courts reviewing the IFPA have already noted that the resulting costs and operational burdens on payment networks could be substantial, with potentially severe consequences for participants across the ecosystem. Credit unions operate on a not-for-profit cooperative model with limited economies of scale, and these costs would fall disproportionately on the nation’s approximately 4,200 credit unions, which rely on interchange revenue to help provide low-cost, secure financial services to our members and communities. A description of the impact on our financial institution may help illustrate the harm that the IFPA and similar legislation in other states could cause. Public Service Credit Union is a state-chartered credit union headquartered in Michigan with $459.4M in assets as of March 31, 2026. Our geographic footprint is the southwest Michigan region. Members use our cards largely within our geographic footprint but may travel from time to time to Illinois and the states that are considering or have passed similar legislation, such as Delaware, Oklahoma and Pennsylvania. Given the size of our credit union, it is not operationally or economically feasible to build, maintain and validate the state-specific transaction-level systems that the IFPA – and similar laws – would require. We are also seriously concerned about the nature of the penalties provision, which if enforced strictly, could have a significant impact on any credit union subject to such laws. Furthermore, the complex manual process workarounds contemplated under the IFPA are not consistent with safe, sound and efficient operations. The IFPA presents substantial operational challenges that we believe the national payments networks will struggle to address in a timely and effective way. As a result, if those networks do not adapt, our practical choices are limited to informing members that their cards may not function in Illinois or engaging in costly and error-prone manual workarounds. Our board and senior management continue to evaluate these risks and consider our options. Sincerely, Lindsey Suter Director of Payments Public Service Credit Union Romulus, Michigan