US Black Chambers, Inc.

May 28, 2026 Office of the Comptroller of the Currency Chief Counsel's Office Attention: Comment Processing 400 7th Street SW Suite 3E-218 Washington, DC 20219 Docket ID: OCC-2026-0431 Re: Comments on OCC Interim Final Rule and Interim Final Order Concerning National Bank Non-Interest Charges and Fees and the Illinois Interchange Fee Prohibition Act Dear Acting Comptroller, On behalf of the U.S. Black Chambers, Inc. (USBC), a national network representing hundreds of Black chambers of commerce and thousands of Black-owned small businesses across the country, I write in support of the Office of the Comptroller of the Currency's interim final order preempting the Illinois Interchange Fee Prohibition Act (IFPA). USBC's mission is to advance economic opportunity for Black entrepreneurs and small business owners. That mission requires us to speak plainly when proposed policies, however well-intentioned, would make it harder for our members to operate, access credit, and compete. The Illinois IFPA is one such policy, and the concerns it raises extend well beyond state lines. The Patchwork Problem Illinois is the first state to restrict interchange fees at this level of specificity, but it will not be the last. Since the IFPA was enacted in 2024, similar legislation has been introduced or advanced in more than a dozen states. If each of those states proceeds with its own rules governing how interchange fees are calculated, which portions of a transaction are covered, and what data can be used in processing payments, the result will be a fragmented, state-by-state compliance landscape that small businesses and their payment processors must somehow navigate. Large national retailers have the legal teams, technology infrastructure, and operational scale to absorb that complexity. The small and minority-owned businesses that make up USBC's membership generally do not. Point-of-sale system upgrades, new compliance workflows, and the risk of inadvertent violations carry real costs that fall disproportionately on smaller operators. The OCC is right to identify the patchwork effect as a serious risk, and right to act before it takes hold. The Impact on Credit Access and Community Banking Interchange fees are not simply a line item for large financial institutions. They fund the fraud protection systems, low-cost checking products, and small-dollar lending that community banks and credit unions provide to underserved markets. Many of USBC's members and the consumers they serve rely on exactly these products. Policies that compress interchange revenue without accounting for those downstream effects risk reducing access to credit and basic banking services for the communities that can least afford it. If the Illinois law is allowed to stand, it could tighten credit standards, reduce the availability of low-limit and no-annual-fee cards, and push lower-income consumers toward payday lenders and other less regulated alternatives. These are not hypothetical concerns. They reflect the real financial landscape that many Black entrepreneurs and their customers navigate every day, and they deserve serious weight in the OCC's analysis. In Conclusion A stable, nationally consistent payments system is foundational to small business growth. The Illinois IFPA undermines that stability, and the prospect of similar laws proliferating across the country compounds the risk. USBC supports the OCC's determination that federal law preempts the IFPA and urges the agency to finalize the interim final order without modification. We appreciate the OCC's attention to these issues and welcome further dialogue on policies that support small business access to affordable, reliable financial services. Sincerely, Ron Busby Sr. President & CEO U.S. Black Chambers, Inc.