ICBA sent a letter to the OCC in support of its interim final order concluding that federal law preempts the Illinois Interchange Fee Prohibition Act as applied to national banks and federal savings associations.

ICBA said the order applies the conflict preemption standard of Barnett Bank and Cantero, protects the uniform national operation of the payment card system, and acts on the kind of good cause that interim final rulemaking exists to address.

ICBA urged the agency to finalize the order without delay and to continue its work with federal and state counterparts to address the broader patchwork of state interchange legislation.