Conference of State Bank Supervisors

Summary: The Conference of State Bank Supervisors (CSBS) opposes the OCC's interim final order because it relies on a flawed and "concocted" preemption standard that is inconsistent with Supreme Court precedent. They argue that the current analysis fails to properly assess whether the Illinois Interchange Fee Prohibition Act (IFPA) significantly interferes with national bank powers, which could lead to protracted litigation and uncertainty for both national and state-chartered banks.