Form Letter 1 - Scott Bromberg - 1st identified, there are 8 similar form letters, there are a total of 9 received.
Scott BrombergOpposeIndividual
Summary: Scott Bromberg argues that the interim final rule obstructs state-level efforts to reform credit card swipe fees and allows card networks to set excessive banking fees. He contends that these fees unfairly burden merchants who act as tax collection agents and ultimately increase costs for consumers.
Dear Regulators:
I write to urge the Office of the Comptroller of the Currency (OCC) to rescind the interim final rule "National Bank Non-Interest Charges and Fees (Docket ID OCC-2026-0430-0001). This rule obstructs the ability for states to enact credit card swipe fee reforms for merchants and consumers and creates an overreaching federal avenue for Visa and Mastercard to set other non-swipe fees like banking late fees, ATM fees, and annual fees.
Merchants must pay expensive swipe fees to accept credit and debit cards as payment from their customers. The hidden fees negatively impact U.S. consumers because retailers are forced to incorporate these fees in their pricing decisions and sell items at the credit card price to cover costs.
At the state level, grocers and other main street merchants act as state and local governments' agents in the collection and submission of state and local sales and excise taxes. Grocers pay credit card swipe fees to the card networks and the nation's largest banks on top of the taxes that are passed through to state and local governments. State reform legislation would prohibit swipe fees from being applied to the state and local taxes, and gratuity in some states, on a portion of the sale.
Grocers and main street merchants are being taxed twice for this official government duty by having to pay credit card swipe fees to the card networks and the nations largest banks, just because they are a pass-through agent for state and local government taxes. In 2024 alone, these taxes on taxes resulted in nearly $11 billion in swipe fees to the card networks and the largest banks from sales tax collection.
The "National Bank Non-Interest Charges and Fees" interim final rule is an overreach by the federal government to obstruct state swipe fee reforms. The rule also creates a dangerous federal avenue for Visa and Mastercard to set other banking fees that are charged to banking customers. I respectfully request that the OCC rescind the "National Bank Non-Interest Charges and Fees" interim final rule.
Thank you.
Scott Bromberg