Coalition LetterNovember 11, 2026

Coalition Comments on State Bank Parity, RIN 3064-AG34

To
Jennifer M. Jones, Deputy Executive Secretary, Federal Deposit Insurance Corporation
Led by
Southwest Public Policy Institute
Re
RIN 3064-AG34
Signed for SPPI
Patrick M. Brenner and Gregory A. Schroeder

The Southwest Public Policy Institute and 22 other organizations and individuals urged the Federal Deposit Insurance Corporation to finalize its proposed State Bank Parity rule (RIN 3064-AG34). The rule would apply a host state’s laws to an out-of-state state bank’s services only as far as they apply to an out-of-state national bank, whether or not the state bank has a branch there: the parity Congress wrote into section 24(j) of the Federal Deposit Insurance Act.

The letter shows what the gap costs. A federal court has barred Illinois from enforcing its Interchange Fee Prohibition Act against national banks, but a state bank serving Illinois customers from another state can’t tell whether the law reaches it. By the FDIC’s estimate, the rule would spare the 3,185 state banks the law may reach about $308 million in one-time system upgrades. The letter asks the FDIC to finalize the rule before the Illinois law takes effect on July 1, 2027.

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