OCC Interpretive Letter 1192, dated May 12, 2026, states that national banks are not required to comply with state money transmitter licensing requirements where those requirements would condition the exercise of federally authorized banking powers. The letter remained an important federal-state boundary issue during the July 18 to August 1, 2026 period.
What changed
The OCC took the position that certain state money transmitter licensing laws are preempted as applied to national banks when they interfere with authorized bank powers.
Compliance perspective
National banks, bank partners, and nonbank service providers should assess where payments activity is being booked and who is the legal actor for licensing purposes. The letter does not erase all state issues, but it can materially change licensing analysis when a national bank is the entity conducting the activity.
Key date
Effective date: May 12, 2026.
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