Illinois Interchange Fee Prohibition Act: OCC Interim Order Comments

The Retail Industry Leaders Association (RILA), Merchant Advisory Group (MAG), and National Restaurant Association (NRA submitted this comment letter in response to the Office of the Comptroller of the Currency's proposed Interim Order that would preempt the Illinois Interchange Fee Prohibition Act (IFPA). The letter argues that the IFPA provides targeted relief for merchants by prohibiting interchange fees on the tax and gratuity portions of electronic payment transactions while preserving the vast majority of existing interchange fee revenue. 

The comment letter explains why the organizations believe the OCC's preemption analysis is unsupported by substantial evidence and misapplies federal banking law. It details how payment card networks—not issuing banks—set and calculate interchange fees, and argues that the Illinois law does not significantly interfere with national bank powers. The organizations also highlight the potential benefits of the IFPA for retailers, restaurants, and consumers facing rising payment acceptance costs. 

This resource is valuable for retail executives, public policy professionals, compliance teams, payment experts, and policymakers monitoring interchange fee regulation and payment card network competition. Download the letter to understand the retail industry's position on interchange fee reform, state consumer protection authority, and the future of payment acceptance costs.