National Bank Non-Interest Charges and Fees
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- Title
- National Bank Non-Interest Charges and Fees
The OCC is adopting an interim final rule to clarify that national banks’ power to charge non-interest charges and fees includes the power to assess, collect, impose, levy, receive, reserve, take, or otherwise obtain noninterest charges and fees, including interchange fees from credit and debit card operations. Further, the interim final rule explains that national banks may charge non-interest charges or fees, even when such charges and fees are set by or in consultation with third parties. The OCC invites public comments on this interim final rule.
- Posted
- Apr 29, 2026
- Comment period
- Apr 29, 2026 – May 30, 2026
- FR Doc
- 2026-08328
- CFR
- 12 CFR Part 7
- Topics
Overview
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Stance breakdown
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Comments over time
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Support × commenter type
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Issues raised
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Position map
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Issues shown
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| Organization | Preemption of state interchange laws | Federal preemption of state laws | Procedural invalidity and notice | Impact of state interchange laws | National bank preemption |
|---|---|---|---|---|---|
7-Eleven BusinessOppose 7-Eleven, Inc. | · | · | · | · | · |
Advancing Black Businesses Foundation AdvocacySupport The Advancing Black Businesses Foundation supports the OCC's interim final rule, arguing that it provides necessary clar | · | · | · | · | · |
American Bankers Association Trade associationSupport The American Bankers Association and 52 state and territorial bank associations support the OCC's interim final rule and | · | · | · | · | |
American Express BusinessSupport American Express National Bank supports the OCC's interim final rule and order, which clarify that national banks have t | · | · | |||
Bank of America, N.A. BusinessSupport Bank of America, N.A. | · | · | · | · | |
Blarney Castle Oil Co. BusinessOppose Blarney Castle Oil and Propane opposes the interim final rule and order, arguing that they would allow national banks to | · | · | · | · | |
BluPeak Credit Union UnionSupport BluPeak Credit Union supports the interim final rule and urges the OCC to codify it to clarify national banks' power to | · | · | |||
Boulder Dam Credit Union BusinessSupport Boulder Dam Credit Union supports the interim final rule and urges the OCC to codify it into a final rule. | · | · | |||
Capital One Financial Corporation BusinessSupport Capital One Financial Corporation strongly supports the proposed Interim Final Rule and Interim Final Order, arguing tha | · | · | · | · | |
Chicago Urban League AdvocacySupport The Chicago Urban League supports the OCC's interim final rule, arguing that clear federal standards for non-interest ch | · | · | · | · | · |
Christian Employers Alliance AdvocacySupport The Christian Employers Alliance supports the OCC's interim final rule, arguing that it protects the national banking sy | · | · | |||
Commerce Bank BusinessSupport Commerce Bank, a regional bank holding company, supports the OCC's interim final rule and urges the agency to codify it | · | · | · | · | |
Cubby's Inc. BusinessOppose Cubby’s Inc., a family-owned convenience and fuel retailer, opposes the interim final rule because it reinforces a syste | · | · | · | · | |
Demand Progress Education Fund AdvocacyOppose A coalition of advocacy organizations and a law professor opposes the OCC's interim final rule, arguing that it is a mis | · | · | · | · | |
EZ Stop Food Marts BusinessOppose EZ Stop Food Marts, a family-owned convenience retail business, opposes the interim final rule because it allows nationa | · | · | · | · | |
Family Fare Convenience Stores BusinessOppose Family Fare, a small retail convenience store chain, opposes the interim final rule because it allows national banks to | · | · | · | · | |
Financial Plus Credit Union BusinessSupport Financial Plus Credit Union supports the interim final rule because it clarifies the power of national banks to charge f | · | · | |||
Frontwave Credit Union UnionSupport Frontwave Credit Union expresses appreciation for and urges the OCC to codify the interim final rule regarding national | · | · | |||
Fuel Iowa AdvocacyOppose FUELIowa, representing small business convenience stores and fuel marketers, opposes the interim final rule and order be | · | · | · | · | |
Heritage South Community Credit Union UnionSupport Heritage South Community Credit Union supports the interim final rule and urges the OCC to codify it to clarify that nat | · | · | |||
Independent Community Bankers of America AdvocacySupport The Independent Community Bankers of America (ICBA) strongly supports the OCC's interim final rule, arguing that it clar | · | · | |||
Innovative Payments Association Trade associationSupport The Innovative Payments Association (IPA), a trade organization representing the electronic payments sector, supports th | · | · | |||
Institute for Policy Innovation AdvocacySupport The Institute for Policy Innovation supports the OCC's interim final rule, arguing that it correctly preempts Illinois's | · | · | |||
JPMorganChase BusinessSupport JPMorgan Chase Bank, N.A. | · | · | · | · | |
Kwik Trip BusinessOppose Kwik Trip, a retail company, opposes the interim final rule and order because they argue it allows banks to collect exce | · | · | · | · | |
Marquette Bank BusinessSupport Marquette Bank, an Illinois state-chartered commercial bank, supports the OCC's Interim Final Rule and Order. | · | · | · | · | · |
Mastercard International Incorporated BusinessSupport Mastercard supports the OCC's interim final rule and order, arguing that the Illinois Interchange Fee Prohibition Act (I | · | · | |||
Michigan State University Federal Credit Union AdvocacySupport Michigan State University Federal Credit Union (MSUFCU) supports the OCC's interim final rule and urges the agency to co | · | · | · | · | |
Mississippi Bankers Association AdvocacySupport The Mississippi Bankers Association supports the OCC's actions to preempt the Illinois Interchange Fee Prohibition Act, | · | · | · | · | · |
Monterra Credit Union UnionSupport Monterra Credit Union supports the interim final rule and urges the OCC to codify it, as it clarifies the power of natio | · | · | |||
National Association of College Stores AdvocacyOppose The National Association of College Stores (NACS) opposes the interim final rule, arguing that it allows national banks | · | · | · | · | |
National Grocers Association AdvocacyOppose The National Grocers Association (NGA) opposes the OCC's interim final rule and order, arguing that they depart from lon | · | · | · | · | · |
National Taxpayers Union AdvocacySupport A coalition of advocacy organizations, including the Competitive Enterprise Institute and the Center for a Free Economy, | · | · | |||
Nouria Energy Corporation BusinessOppose Nouria Energy Corporation, a family-owned fuel retailer and convenience store operator, opposes the interim final rule a | · | · | · | · | |
Pathward, N.A. BusinessSupport Pathward, N.A., a national bank operating in the payments and financial technology space, supports the OCC's interim fin | · | · | · | · | |
Payments Leadership Council AdvocacySupport The Payments Leadership Council (PLC), representing a coalition of major banks and payment networks, supports the OCC's | · | · | · | ||
Petroleum and Convenience Marketers of Alabama Trade associationOppose The Petroleum & Convenience Marketers of Alabama (P&CMA), a state trade association, opposes the interim final rule and | · | · | · | · | |
Retailers Association of Massachusetts Trade associationOppose The Retailers Association of Massachusetts is urging the OCC to rescind the "National Bank Non-Interest Charges and Fees | · | · | · | · | · |
Rmarts LLC BusinessOppose Rmarts LLC, a convenience retailer, opposes the interim final rule and order because they believe it allows national ban | · | · | · | · | |
Rosedale Bank BusinessSupport Rosedale Bank, a federally-chartered mutual savings association, supports the OCC's interim final rule and pre-emptive o | · | · | |||
Small Business & Entrepreneurship Council (SBE Council) AdvocacySupport The Small Business & Entrepreneurship Council (SBE Council) supports the OCC's interim final rule and order, arguing tha | · | · | |||
Southwest Public Policy Institute AdvocacySupport The Southwest Public Policy Institute (SPPI), a nonprofit think tank, supports the OCC's interim final rule to preempt t | · | · | · | ||
St. Louis Community Credit Union Trade associationSupport The commenter, representing a credit union, supports the OCC's interim final rule clarifying that national banks have th | · | · | |||
The Hub Convenience Stores, Inc. (dba The Hub) BusinessOppose The Hub Convenience Stores, Inc. | · | · | · | · | |
The Minnesota Service Station & Convenience Store Association AdvocacyOppose The Minnesota Service Station & Convenience Store Association (MSSA) opposes the interim final rule, arguing that it all | · | ||||
The National Bankers Association Trade associationSupport The National Bankers Association (NBA), a trade association representing Minority Depository Institutions (MDIs), strong | · | · | |||
The New York Association of Convenience Stores Trade associationOppose The New York Association of Convenience Stores (NYACS), a trade organization representing neighborhood convenience store | · | · | · | · | |
Toot'n Totum Food Stores LLC BusinessOppose Toot’n Totum Food Stores LLC, a Texas-based convenience store and travel center company, opposes the interim final rule | · | ||||
United Pacific BusinessOppose United Pacific, a retail gas station and convenience store operator, opposes the interim final rule and order because th | · | · | · | · | |
USAA Federal Savings Bank BusinessSupport USAA Federal Savings Bank supports the OCC's rule on National Bank Non-Interest Charges and Fees and the interim final o | · | · | · | · | · |
Varo Bank N.A. BusinessSupport Varo Bank, a digital national consumer bank, strongly supports the OCC's interim final rule and order because they belie | · | · | |||
Velera BusinessSupport Velera Solutions, LLC, a payments technology company representing over 4,000 financial institutions, supports the OCC's | · | · | · | · | |
Virginia Bankers Association Trade associationSupport The Virginia Bankers Association (VBA) strongly supports the OCC's interim final rule and order, arguing that they provi | · | · | |||
W&H Cooperative Oil Company BusinessOppose W&H Cooperative Oil Company, an independent energy cooperative, opposes the interim final rule and order because they be | · | · | · | · | |
Washington Food Industry Association Trade associationOppose The Washington Food Industry Association (WFIA), a trade association representing independent supermarkets and convenien | · | · | |||
Wawa, Inc. BusinessOppose Wawa, Inc., a large convenience store chain, opposes the proposed rule and order because they believe it authorizes nati | · | · | · | · | |
Wisconsin Bankers Association Trade associationSupport The Wisconsin Bankers Association (WBA) supports the OCC's interim final rule and order, which clarify that national ban | · | · | · | · |
5 organization-typed comments could not be identified.
Explorer
Every mirrored comment — filter by stance, campaign, or issue.
- May 29, 2026National Association of College StoresOpposeAdvocacy📎 Attachment
The National Association of College Stores (NACS) opposes the interim final rule, arguing that it allows national banks to collect fees centrally fixed by third-party companies like Visa and Mastercard, which they claim will lead to higher costs for students and businesses. They urge the OCC to withdraw the rule and the related interim final order, citing concerns over anticompetitive fee-fixing and the lack of a proper notice-and-comment process.
Read comment → - May 29, 20267-ElevenOpposeBusiness📎 Attachment
7-Eleven, Inc. opposes the OCC's interim final rule and order, arguing that the actions undermine state efforts to exempt sales taxes and gratuities from interchange fees. The company contends that these fees are a significant operating cost and that the OCC bypassed the standard notice-and-comment process, depriving impacted businesses of a meaningful opportunity to provide input.
Read comment → - May 28, 2026Robert Shapiro, Ph.D.OpposeAcademic📎 Attachment
Dr. Robert Shapiro, an economic analyst and Senior Policy Fellow at the Georgetown University School of Business, argues that exempting sales taxes and gratuities from interchange fees will not lower consumer prices. He contends that the move will increase operational costs for retailers and banks while likely leading banks to recoup lost revenue by raising fees for their customers.
Read comment → - May 22, 2026Scott BrombergOpposeIndividual
Scott Bromberg argues that the interim final rule obstructs state-level efforts to reform credit card swipe fees and allows card networks to set excessive banking fees. He contends that these fees unfairly burden merchants who act as tax collection agents and ultimately increase costs for consumers.
Read comment →
