OCC Action Could Preserve a Uniform National Payments System

The payments industry is closely watching a recent proposal from the Office of the Comptroller of the Currency (OCC) that could have significant implications for banks, payment providers, merchants, and consumers nationwide. The OCC has proposed clarifying that national banks and federal savings associations retain the authority to assess non-interest charges and fees, including interchange fees, and that certain provisions of Illinois' Interchange Fee Prohibition Act (IFPA) are preempted by federal law.

The Innovative Payments Association (IPA) recently submitted comments supporting the OCC's proposals, highlighting concerns that state-level restrictions on interchange fees and payment data usage could create operational challenges across the payments ecosystem. The association noted that many modern financial products and services rely on a seamless, nationwide payments infrastructure supported by consistent regulatory standards.
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Beyond Illinois, similar legislative efforts are emerging in other states, raising broader questions about how the U.S. payments system can continue to operate efficiently if differing state requirements begin to govern core payment functions. A fragmented regulatory framework could increase complexity for financial institutions and payment providers while potentially impacting the products and services consumers rely on every day.

The IPA believes the OCC's action provides important clarity for the industry and helps maintain the uniform national framework that supports secure, reliable, and widely accepted electronic payments. As policymakers continue to debate the future of interchange regulation, these issues will remain critical to the stability and efficiency of the payments ecosystem.

For additional details and the IPA's full analysis, download and read the complete comment letter.

Download Comment Letter