National Bank Non-Interest Charges and Fees: Interim Final Rule

Impact. This interim final rule establishes new OCC standards governing how national banks structure and disclose non-interest charges and fees to customers. Your institution must review all fee structures against these new standards and update disclosure practices, fee calculation systems, and staff training to ensure compliance by the June 2026 effective date.

Risk. Consumer protection examinations will scrutinize fee transparency and fairness, with particular attention to how fees are calculated, disclosed, and processed. Customer-facing operations present the highest exposure since staff interactions directly affect compliance with new disclosure obligations and fee collection practices.

Recommended Action. Have legal counsel obtain and review the full rule text immediately to understand specific fee standards and disclosure requirements. Compliance should then conduct a comprehensive inventory of all current non-interest fees and charges to identify gaps against the new OCC framework.

Watch. Monitor for the OCC's comment period closure and any subsequent modifications to the interim final rule that could alter implementation requirements or timelines. Track industry guidance and examination bulletins that will clarify enforcement expectations as the 2026 effective date approaches.