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IBA and ABA Issues Guide for Banks Writing Comment Letters on OCC Interim Final Rule

5/7/2026

The Illinois Bankers Association and the American Bankers Association has released a guide for banks to use when writing comment letters supporting the OCC’s recent interim final rule clarifying national banks’ power to charge interchange fees from credit and debit card operations, in support of the IBA’s interchange litigation. The guide includes a sample comment letter for banks to customize and practical suggestions. Comments to the interim final rule are due by May 29, 2026. Access the guide.
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