Advancing Black Businesses Foundation

5/26/26 Office of the Comptroller of the Currency Chief Counsel’s Office 400 7th Street SW Washington, DC 20219 Subject: National Bank Non-Interest Charges and Fees Dear Comptroller Gould: Advancing Black Businesses Foundation appreciates the opportunity to provide comments regarding the OCC’s interim final rule addressing National Bank Non-Interest Charges and Fees. Our organization works to expand economic opportunities and strengthen financial access for Black communities. We believe the OCC’s action provides important clarity that will help national banks continue delivering affordable banking services in a safe, sustainable, and innovative manner. For many families, particularly in historically Black communities, access to mainstream banking remains one of the most important foundations for financial security. Affordable transaction accounts, digital payment tools, and secure banking services allow consumers to participate fully in the economy, build savings, and avoid reliance on costly alternative financial services. The operational systems required to maintain these services including fraud prevention, payment processing, customer support, cybersecurity, and account maintenance—carry significant costs. Non-interest fee revenue helps financial institutions support these essential functions while continuing to offer accessible banking products to consumers across income levels. Without stable and regulated banking options, many consumers are forced toward higher cost alternatives such as payday lenders, check-cashing businesses, and other non-bank financial products that often create long-term financial hardship. Communities already facing economic challenges are disproportionately impacted by these practices. We believe the OCC’s rule helps preserve a consistent national banking framework that supports financial inclusion, consumer protection, and continued innovation in payment systems. Regulatory uncertainty in this area could unintentionally reduce access to affordable accounts and weaken progress made toward bringing more households into the mainstream banking system. For these reasons, we support finalization of the interim final rule and encourage the OCC to continue advancing policies that strengthen access to responsible financial services for all communities. Thank you for your consideration and for your continued leadership in promoting a safe, inclusive, and accessible banking system. Sincerely, Markee Tate President/Chair Advancing Black Businesses Foundation