The Association of Military Banks of America (AMBA) submitted a comment letter on behalf of AMBA member banks supporting the Office of the Comptroller of the Currency’s (OCC’s) interim final rule preempting Illinois’ Interchange Fee Prohibition Act (IFPA), arguing the law threatens the stability and uniformity of the national banking system. AMBA and other trade groups in separate comment letters have emphasized that national banks and payment networks depend on consistent federal standards to process transactions efficiently, manage cybersecurity risks, and provide seamless services across state lines (Tab A).
In the letter, AMBA’s CEO also warns that the IFPA would create major operational burdens by requiring payment systems to separate taxes and gratuities in real time while navigating varying state requirements. Most importantly, the letter emphasizes that military banks could face unique challenges because servicemembers and military families rely on uninterrupted nationwide banking access during frequent relocations. The association further cautioned that rising compliance costs could reduce resources available for specialized programs and services supporting military communities.
AMBA praised the OCC’s swift action ahead of the law’s July 1, 2026, effective date, saying delays could have caused market disruption and uncertainty.