Consumer Action for a Strong Economy

Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW Suite 3E-218 Washington, DC 20219 Re: Interim Final Rule: National Bank Non-Interest Charges and Fees RIN 1557-AF54; Docket ID OCC-2026-0430 Interim Final Order: Order Preempting the Illinois Interchange Fee Prohibition RIN 1557–ZA10, Docket ID OCC–2026–0431 Dear Comptroller, Consumer Action for a Strong Economy exists to serve as the voice of American consumers by limiting government control over markets and advocating for free-market principles that deliver lower costs and greater consumer choice. Too many organizations claim to speak for consumers, yet still endorse heavy-handed regulation that shrinks options and drives up prices. We write today to offer a pro-consumer perspective on the OCC’s action to preempt the Illinois Interchange Fee Prohibition Act. CASE has consistently opposed empty regulations sold as consumer safeguards, just as the IFPA does. Interchange fees are deeply misunderstood. They are not for profit but a mechanism by which card issuers fund fraud protection, consumer rewards programs, and the infrastructure that enables seamless, secure card payments. The IFPA mandates an immediate technical capability that does not exist anywhere in the current payments infrastructure, and the consequences of forcing compliance with an operationally unachievable mandate will be devastating. Banks facing impossible demands will be forced to scale back services and limit card acceptance. The rewards that working families have come to count on become less generous, and the protection that shields consumers from fraud weakens. The payment experience, which has become a basic expectation of modern commerce, becomes entirely less reliable. These are the practical consequences of government interference in a market that, by virtually every measure, has served consumers well. CASE is acutely aware of what happens when one state successfully rewrites the rules of a national network. States monitoring developments in Illinois will interpret any failure to preempt the IFPA as permission to follow suit. The result would be a fragmented patchwork of state interchange mandates, each with its own requirements, adding to the compliance burden and making it more expensive and more complicated to serve consumers. The OCC’s action prevents that outcome. We commend the OCC for acting decisively before the IFPA’s effective date, and we urge the agency to finalize and defend this position. American consumers are best served by a payments system governed by uniform federal standards. Sincerely, Consumer Action for a Strong Economy 1800 Diagonal Road, Suite 600 Alexandria, VA 22314 www.CASEforConsumers.org