American Express National Bank
American ExpressSupportBusiness
Summary: American Express National Bank supports the OCC's actions to preempt the Illinois Interchange Fee Prohibition Act (IFPA), arguing that the current interpretation of "charging" fees aligns with commercial reality. The bank further urges the OCC to explicitly extend this preemption to non-bank third parties, such as networks and processors, to prevent state laws from interfering with national banks' contracting powers.
Please see enclosed for a comment letter from American Express National Bank providing feedback on the OCC's Interim Final Actions on National Bank Fees and IFPA Preemption (Docket ID OCC-2026-0431)