Bank Policy Institute, Consumer Bankers Association, Financial Services Forum, and The Clearing House

Summary: The Bank Policy Institute, The Clearing House Association L.L.C., the Consumer Bankers Association, and the Financial Services Forum strongly support the OCC's order and rule. They argue that the Illinois Interchange Fee Prohibition Act (IFPA) is preempted by the National Bank Act because it significantly interferes with national banks' federally authorized powers to receive compensation for payment card services. The commenters contend that the IFPA would cause substantial revenue losses, impose high compliance costs, and undermine the security and efficiency of the national payment card ecosystem.