Institute of International Bankers
Institute of International BankersSupportTrade association
Summary: The Institute of International Bankers (IIB) supports the OCC's order preempting the Illinois Interchange Fee Prohibition Act. They argue that the state law creates operational risks, threatens the integrity of the national banking system, and would lead to a fragmented, complex, and inefficient payments ecosystem.
The Institute of International Bankers welcomes the opportunity to submit the attached response to the Interim Final Rule: National Bank Non-Interest Charges and Fees and the Interim Final Order: Order Preempting the Illinois Interchange Fee Prohibition RIN 1557–ZA10, Docket ID OCC–2026–0431.