Chief Counsel’s Office Attention: Comment Processing Office of the Comptroller of the Currency 400 7th Street SW, Suite 3E-218 Washington, DC 20219
Re: Interim Final Rule: RIN 1557-AF54; Docket ID OCC-2026-0430; Interim Final Order: RIN 1557-ZA10, Docket ID OCC-2026-0431
To whom it may concern:
The Christian Employers Alliance respectfully submits this comment in strong support of the Office of the Comptroller of the Currency’s Interim Final Rule and Interim Final Order concerning the Illinois Interchange Fee Prohibition Act. We appreciate the OCC’s prompt action to protect the national banking system from a state law that would disrupt the uniform legal framework on which interstate commerce and nationwide access to financial services depend.
Congress established the national banking system to facilitate interstate commerce and ensure consistent, dependable access to financial services nationwide. That framework has allowed banks to offer lower-cost products and services at scale, including to consumers, families, and small businesses in underserved communities. A uniform regulatory system rather than a patchwork of conflicting state mandates has also enabled the development of the modern payments ecosystem, including the debit and credit card networks that businesses rely on every day to process transactions quickly, securely, and efficiently.
From the perspective of the Christian Employers Alliance and our Biblical Business Index (BBI) framework, stable financial infrastructure and predictable regulatory environments are essential to healthy commerce and human flourishing. The BBI evaluates how laws and regulations affect the ability of businesses to operate freely, ethically, and sustainably while promoting economic opportunity, responsible stewardship, and long-term stability. Policies that fragment national markets or impose inconsistent regulatory obligations undermine those goals and create unnecessary burdens for employers, workers, and consumers alike.
The Illinois law threatens to upend that system by prohibiting banks, credit unions, and payment networks from charging interchange fees on the tax and tip portions of electronic payment transactions. If allowed to stand, this measure would fracture nationwide payment operations and impose extraordinary compliance burdens on institutions that operate across state lines. For Christian business owners and employers, predictable access to efficient payment systems is not an abstract concern; it is essential to meeting payroll, serving customers, managing cash flow, and sustaining ministries, charities, and family-owned enterprises that depend on reliable financial infrastructure.
The law is also unworkable in practice. Its effective date is approaching, yet no existing technology can consistently separate taxes and tips from the total transaction amount to calculate interchange fees across the full range of retail settings. In some industries, such as fuel sales, taxes are embedded in the total purchase amount, making real-time separation especially difficult. Faced with the risk of substantial penalties for noncompliance, banks and networks may be forced to alter or even decline certain transactions. That outcome would create confusion at checkout, delay legitimate purchases, and inject instability into payment processing for merchants and consumers alike.
Just as troubling, the law’s restrictions on data usage would impair fraud detection, risk management, and other core safeguards that protect account holders and merchants. Interchange revenue helps support rewards programs, card security investments, and broader access to low-cost payment products. Weakening those protections would expose consumers and businesses to greater fraud risk while increasing operational costs across the financial system.
If states can selectively dismantle that framework, the result will be higher costs, fewer cardholder benefits, reduced innovation, and greater exposure to fraud and litigation. Small businesses will not be insulated from these harms; they are likely to bear them first, whether through slower processing, higher prices, or diminished access to payment tools that are vital to commerce. Under the BBI framework, these kinds of regulatory distortions undermine economic resilience and weaken the conditions necessary for businesses and communities to thrive.
More broadly, this is a case of state overreach into a national market that depends on consistency, not fragmentation. Additional government intervention of this kind will hamper competition, increase costs for consumers and employers, and undermine confidence in the payment systems that support the American economy. Christian employers, like other business owners, need rules that promote stability, lawful uniformity, innovation, and the freedom to operate in a market that is not distorted by conflicting state-by-state mandates.
For these reasons, we strongly support the OCC’s Interim Final Rule and Interim Final Order and urge the agency to continue exercising its authority to preserve the integrity, uniformity, and stability of the national banking system.
Respectfully submitted,
Margaret Iuculano President Christian Employers Alliance
Margaret Iuculano (margaret@christianemployersalliance.org) is the president of the Christian Employers Alliance, promoting policies that support religious freedom and biblical principles in the workplace.
The Christian Employers Alliance advocates for Christian employers nationwide, defending against government mandates and promoting policies that support religious freedom and biblical principles in the workplace. Through initiatives like the Biblical Business Index (BBI), CEA provides the transparency and tools necessary for business leaders to lead with a record of conviction.
Established in 2016, CEA is a national 501(c)(3) non-profit organization. CEA serves as the voice for America’s top Christian CEOs, spanning from Wall Street to Main Street.
To learn more about Christian Employers Alliance please visit ChristianEmployersAlliance. You can follow CEA on X, Facebook, and LinkedIn.