National Retail Federation

Summary: The National Retail Federation (NRF) opposes the OCC's interim final order and rule, arguing that the Illinois Interchange Fee Prohibition Act (IFPA) is a valid state law that should not be preempted. They contend that the OCC is exceeding its statutory authority, violating procedural requirements of the Administrative Procedure Act, and attempting to protect an anticompetitive interchange fee system that burdens retailers and consumers.