News & Analysis as of

Interchange Fees

Orrick, Herrington & Sutcliffe LLP

FDIC orders state bank to pay $1.375B

On April 18, the FDIC announced that it amended its 2023 consent order against an insured state nonmember bank, as well as issued a new order for restitution and order to pay, concluding the bank recklessly engaged in unsafe...more

Ballard Spahr LLP

Republicans ask federal banking agencies to withdraw rules, guidance

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Republicans on the House Financial Services Committee have sent letters to financial regulators asking them to rescind a variety of measures the regulators issued during the Biden Administration....more

Orrick, Herrington & Sutcliffe LLP

District court grants partial preliminary injunction in case challenging Illinois law on interchange fees

Recently, the U.S. District Court for the Northern District of Illinois Court granted a partial preliminary injunction sought by banking associations against the Illinois Attorney General over the Illinois Interchange Fee...more

Ballard Spahr LLP

Illinois swipe fee injunction extended to cover out-of-state banks, but not federal credit unions

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Chief Judge Virginia Kendall of the Northern District of Illinois has extended her preliminary injunction prohibiting Illinois from enforcing the Illinois Interchange Fee Prohibition Act (the “IFPA”) to cover out-of-state...more

Hudson Cook, LLP

CFPB Bites of the Month - 2024 Annual Review - Credit Cards

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In this article, we share a timeline of our monthly "bites" for 2024 applicable to the credit card industry. The year saw the CFPB give a fair amount of attention to credit card products, with a focus on pricing....more

Blank Rome LLP

Illinois Loses First Shot at Interchange Fees on State and Local Taxes

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Illinois enacted a law that prohibits a credit card holder’s bank from charging or receiving interchange fees on the portions of transactions that include Illinois state or local taxes and gratuities, in effect starting July...more

Moore & Van Allen PLLC

Developments in National Bank Act (NBA) Preemption: Illinois’ Interchange Fee Prohibition Act is Held Preempted by the NBA; Ninth...

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For followers of developments related to National Bank Act (NBA) preemption and the United States Supreme Court’s related decision in Cantero v. Bank of America, N.A., 602 U.S. 205 (2024), the waning days of 2024 proved...more

Ballard Spahr LLP

Court grants partial injunction for National Banks and Federal Savings Associations in the lawsuit challenging the Illinois...

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In a 37 page order, Chief Judge Virginia M. Kendall in the Northern District of Illinois determined that the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union...more

Orrick, Herrington & Sutcliffe LLP

District Court case on interchange fees moves forward with intervenor motion

Recently, the U.S. District Court for the District of North Dakota received a motion from two banking associations seeking intervenor status in a case challenging Regulation II, which regulates interchange fees received by...more

Ballard Spahr LLP

Industry groups file motion to intervene in Corner Post debit card interchange case

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On October 16, 2024, the Bank Policy Institute and the Clearing House Association filed a motion to intervene in Corner Post, Inc. v Board of Governors of the Federal Reserve System. On July 1, 2024, the Supreme Court sided...more

Troutman Pepper Locke

Troutman Pepper Weekly Consumer Financial Services Newsletter- October 2024 # 3

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To keep you informed of recent activities, below are several of the most significant federal and state events that have influenced the Consumer Financial Services industry over the past week...more

Troutman Pepper Locke

The OCC and Illinois Attorney General File Opposing Briefs on Interchange Fee Prohibition Act

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On October 2, the Office of the Comptroller of the Currency (OCC) filed an amicus brief in the U.S. District Court for the Northern District of Illinois in support of several banking associations’ motion for a preliminary...more

Sheppard Mullin Richter & Hampton LLP

Swipe Fee Saga Continues: OCC and Trade Groups Clash with Illinois AG

The banking industry’s efforts to challenge a new Illinois law banning interchange fees, also known as “swipe fees,” on tax and tip payments gained significant momentum when the OCC criticized the law as an “ill-conceived”...more

Orrick, Herrington & Sutcliffe LLP

OCC files amicus brief supporting a preliminary injunction on the Illinois’ Interchange Fee Prohibition Act

On October 2, the OCC filed an amicus brief supporting several banking associations’ motion for a preliminary injunction against the Illinois Interchange Fee Prohibition Act (IFPA or the Act) in the U.S. District Court for...more

Arnall Golden Gregory LLP

Illinois Interchange Fee Prohibition Act: The Bill and the Backlash

On May 29, 2024, Illinois rocked the payments world by passing the Interchange Fee Prohibition Act (“IFPA”) into law. With an effective date of July 1, 2025, the law would upend the way in which interchange is calculated in...more

MG+M The Law Firm

Class Actions Involving ATM Fees: Settlement Information and Deadlines

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In October 2011, three related (or parallel) class action lawsuits were filed. These cases named Visa and Mastercard (and others) as defendants but are unrelated to the Interchange Fee case with the $5.5 billion settlement...more

Orrick, Herrington & Sutcliffe LLP

Bank associations sue Illinois to prevent interchange fee act from effecting

On August 15, several banking and credit union associations sued the Illinois Attorney General to prevent the state from implementing the Illinois Interchange Fee Prohibition Act (the “Act”). As covered by InfoBytes, the...more

Ballard Spahr LLP

Bank and Credit Union Industry Groups Challenge Illinois Interchange Fee Prohibition Act as Unlawful and Urge the Court to Stop...

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On August 15, 2024, the Illinois Bankers Association, American Bankers Association, America’s Credit Unions, and Illinois Credit Union League filed a complaint for declaratory and injunctive relief against the Illinois...more

Amundsen Davis LLC

Interchange Fee Prohibition Act

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The Interchange Fee Prohibition Act (IFPA), signed into law in June of 2024 by Illinois Governor J.B. Pritzker, prohibits banks, savings associations, credit union, and others from receiving or charging an interchange fee on...more

Goodwin

SCOTUS Ruling Makes Federal Agency Rules Susceptible to Previously Untimely Challenges

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​​​​​​​At the close of an extended term, on July 1, 2024, the U.S. Supreme Court expanded the time period for bringing a facial challenge to a federal agency rule....more

Morrison & Foerster LLP

When the Right “Accrues”: Corner Post Extends the Statute of Limitations under the Administrative Procedure Act

On July 1, 2024, the U.S. Supreme Court issued a decision in Corner Post, Inc. v. Board of Governors of the Federal Reserve System, holding that an Administrative Procedure Act (APA) claim does not accrue for purposes of the...more

Wiley Rein LLP

SCOTUS Overrules Chevron and Opens Door to More Challenges Under APA: Environmental Law Implications of Loper Bright and Corner...

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The U.S. Supreme Court issued two opinions at the end of its term impacting environmental law. In Loper Bright Enterprises v. Raimondo, the Court held that courts must exercise independent judgment when determining if an...more

Ballard Spahr LLP

Supreme Court Opens Door to More APA Challenges by Ruling that Right of Action Accrues When Regulation First Causes Injury

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On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more

Ballard Spahr LLP

Supreme Court opens the door for more APA challenges by ruling that the right of action accrues when the rule first causes injury

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On July 1, 2024, the Supreme Court issued its opinion in Corner Post, Inc. v Board of Governors of the Federal Reserve System in which the Court determined when a Section 702 claim under the Administrative Procedure Act (APA)...more

Vinson & Elkins LLP

“The Ball is in Congress’ Court”: U.S. Supreme Court in Corner Post Paves the Way for Challenges to Longstanding Treasury...

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In the final decision of the Supreme Court’s term, the Court again considered the Administrative Procedure Act (“APA”). Like earlier decisions this term considering the APA (see here and here), the opinion in Corner Post,...more

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