National Retail Federation

Summary: The National Retail Federation (NRF) opposes the OCC's interim final rule and order, arguing that they improperly preempt Illinois' Interchange Fee Prohibition Act (IFPA) and expand the National Bank Act beyond its statutory authority. The NRF contends that the actions undermine competition, harm retailers and consumers by preserving high interchange fees, and violate procedural requirements of the Administrative Procedure Act and Dodd-Frank Act.