Boulder Dam Credit Union
Boulder Dam Credit UnionSupportBusiness
Summary: Boulder Dam Credit Union supports the interim final rule and urges the OCC to codify it into a final rule. The credit union argues that the rule is necessary to preserve a national card-based payment system and prevent the "staggering" costs and operational complexities that state-level legislation like the IFPA would impose on smaller financial institutions.
We write to express our appreciation to the OCC for the interim final rule clarifying the longstanding powers under federal law for national banks and federal savings associations to charge fees, regardless of whether those fees are set by the bank or by a contract with a third party. We urge the OCC to issue a final rule to codify the interim final rule. We also support and strongly agree with the arguments made in the OCC’s amicus brief related to the Illinois Bankers case in the Seventh Circuit.