OCCGeneralApril 29, 2026

OCC Preempts Illinois Law Banning Interchange Fees on Tax and Tip Portions

The OCC has issued an interim final order concluding that the Illinois Interchange Fee Prohibition Act — which would bar national banks and federal savings associations from charging interchange fees on the tax and gratuity portions of card transactions and restrict use of transaction data — is preempted by federal law. Payment processors and fintechs that issue cards or process transactions for national banks should note that the Illinois restriction will not apply to federally chartered institutions, though state-chartered entities and non-bank payment companies may still need to assess their own exposure.

What to do

Review whether your card program or payment processing agreements involve national banks or federal savings associations, and assess whether any Illinois Interchange Fee Prohibition Act compliance measures already underway can be paused pending the outcome of the comment period on this interim final order.

Who this affects

Bank / Credit UnionPayments CompanyFintech / Neobank

Does this affect your program?

Pick your institution type for an instant read on whether you're in scope — then see exactly which sections of your own policies this changes.

Source

Read the official publication

This radar entry is educational and does not constitute legal advice. Summaries are AI-assisted and grounded in the linked official source; always verify against the primary source and consult qualified legal counsel for jurisdiction-specific guidance.

Related developments

OCC

OCC Updates Cybersecurity Examination Work Program for Banks

The OCC has revised its Cybersecurity Supervision Work Program (CSW), which examiners use to assess cybersecurity risk at national banks and federal savings associations, updating its structure and references to reflect the evolving threat landscape and adoption of standardized frameworks. For compliance and risk officers at banks, neobanks, and trust companies under OCC supervision, this signals updated examiner expectations around cybersecurity controls and preparedness. Crypto custodians and fintechs with bank charters or partnerships should also take note, as vendor and third-party cybersecurity risk is often assessed through this lens.

CFTC

CFTC Updates Whistleblower Award Rules for Greater Transparency

The CFTC is amending its whistleblower program rules to improve efficiency, transparency, and predictability of the claims process, modeled on similar SEC regulations. The amendments also reflect an internal reorganization moving the Whistleblower Office to the Office of General Counsel. Compliance officers at crypto and derivatives firms should be aware that a more streamlined whistleblower process may increase the likelihood of internal misconduct being reported externally to the CFTC.

OCC

OCC Joins Interagency Proposed Third-Party Risk Management Guidance

The OCC is co-issuing the same interagency third-party risk management proposal alongside the Fed, FDIC, and NCUA, signaling a unified supervisory approach across the federal banking agencies. National banks and federal savings associations should treat this as a near-certain indicator of forthcoming binding expectations on vendor oversight. The proposal's emphasis on risk-proportionate controls is particularly relevant for institutions using crypto or fintech service providers.

OCC

OCC/Fed/FDIC Raise Asset Threshold for 18-Month Exam Cycle to $6 Billion

An interim final rule from the OCC, Federal Reserve, and FDIC raises the total asset threshold that allows certain well-managed, well-capitalized insured depository institutions and U.S. branches of foreign banks to qualify for an extended 18-month on-site examination cycle. Smaller banks and trust companies that fall below the new threshold may see reduced examination frequency, affecting the pace of supervisory feedback on compliance programs. Fintech-partnered banks and crypto-custody trust companies under the threshold should be aware that less frequent exams do not reduce compliance obligations.

Stay ahead of every rule change

PliOS monitors FinCEN, OCC, OFAC, the SEC and CFTC and tells you which of your policies each new rule affects — with the edit already drafted. Start free.

Run My Free Assessment