Summary: FDIC State Bank Parity – Notice of Proposed Rulemaking & Request for Comments

Updated 09/29/2026

The Board of Directors of the Federal Deposit Insurance Corporation (FDIC) recently issued a notice of proposed rulemaking intended to modernize and reinforce parity between state-chartered banks and national banks providing cross-border financial services. Prompted largely by recent state-level enactments currently being argued before the courts, such as the Illinois Interchange Fee Prohibition Act, the proposal seeks to prevent a competitive imbalance where national banks claim National Bank Act preemption while out-of-state state banks remain exposed to conflicting state mandates.

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