Consumer Finance Monitor Podcast Episode: Understanding the Federal Reserve Board Proposal to Lower Interchange Fee Cap for Debit Card Transactions
On April 29, 2026, the OCC, a division of the federal Department of the Treasury that regulates nationally chartered banks, issued an interim final rule and order declaring that federal law preempts Illinois’ hotly contested...more
The latest edition of the Fintech Case Files, our roundup of key litigation and enforcement involving the payments and fintech industries, features the latest challenges and uncertainty around Illinois’s Interchange Fee...more
The OCC issued two interim final actions preempting the Illinois Interchange Fee Prohibition Act, causing the Seventh Circuit to vacate and remand related proceedings to the district court....more
The U.S. Court of Appeals for the Seventh Circuit issued a highly significant order on May 8, 2026 in the closely watched litigation challenging the Illinois Interchange Fee Prohibition Act (“IFPA”), vacating the district...more
On May 6, the parties filed simultaneous supplemental briefs in litigation challenging the Illinois Interchange Fee Prohibition Act (IFPA), which remains on appeal before the 7th Circuit, while the OCC and merchant trade...more
On April 7, 2026, the Office of the Comptroller of the Currency (OCC) and the Federal Deposit Insurance Corporation (FDIC, and collectively with the OCC, the “Agencies”) issued a joint final rule eliminating reputation risk...more
On April 17, the Securities and Exchange Commission (SEC) published with immediate effectiveness a New York Stock Exchange (NYSE) proposed rule change that permits the trading of securities on the exchange in tokenized form....more
On April 24, the OCC issued an interim final rule and an interim final order related to the Illinois Interchange Fee Prohibition Act (IFPA), which bans interchange fees on the tax or gratuity portions of a transaction and...more
On April 24, 2026, the Office of the Comptroller of the Currency (OCC) issued two coordinated interim final actions: an Interim Final Rule amending 12 CFR § 7.4002 governing national bank non‑interest charges and fees...more
On April 24, the OCC announced an interim final rule and a related interim final order clarifying national banks’ authority to charge non-interest fees and concluding that federal law preempts the embattled Illinois...more
In April 2026, the Office of the Comptroller of the Currency issued two coordinated interim actions addressing national banks’ authority to impose certain fees. ...more
In a pair of coordinated actions on April 24, 2026, the Office of the Comptroller of the Currency (OCC) moved to reaffirm and expand the scope of National Bank Act (NBA) preemption to credit and debit card interchange fees...more
On April 14, the OCC submitted an interim final rule and a preemption determination to the OMB’s Office of Information and Regulatory Affairs (OIRA) for review under Executive Order 12866 (as amended). The interim final rule,...more
On April 3, the Illinois attorney general filed a combined principal and response brief in the U.S. Court of Appeals for the 7th Circuit, urging the court to affirm the district court’s ruling that the Illinois Interchange...more
The Illinois attorney general (AG) recently filed a brief defending the Illinois Interchange Fee Prohibition Act (IFPA) in an appeal arising out of litigation captioned Illinois Bankers Association v. Raoul. The AG asked the...more
The first three months of 2026 have delivered a number of notable competition litigation developments. So, here are our five developments from this quarter that are worth highlighting. In the latest judgment in the...more
On 31 March 2026, the Reserve Bank of Australia (RBA) published its conclusions paper titled Merchant Card Payments Costs and Surcharging. Key Takeaways The RBA outlined a range of changes including three key reforms to...more
Australia’s payment system has been the subject of a multi-pronged review with proposals for reform at various stages and across various aspects of Australia’s payments ecosystem. At the end of March 2026, the Reserve Bank of...more
Just five weeks after the United States District Court for the Northern District of Illinois largely upheld the Illinois Interchange Fee Prohibition Act (IFPA), on March 16, 2026, the Office of the Comptroller of Currency...more
In February, the court in Illinois Bankers Association v. Raoul found that the Illinois Interchange Fee Prohibition Act does not directly regulate national banks and falls outside National Bank Act, or NBA, preemption because...more
Banks and credit unions are preparing for the loss of interchange fees on Illinois debit and credit card transactions following the court’s decision in Illinois Bankers Association et al. v. Raoul, No. 24-7307 (N.D. Ill. Feb....more
On March 13, the OCC filed an amicus curiae brief in the U.S. Court of Appeals for the 7th Circuit, urging the court to reverse the district court’s ruling on the Illinois Interchange Fee Prohibition Act’s (IFPA) interchange...more
The UK Payment Systems Regulator (PSR) has published an invitation to comment on a revised draft questionnaire for a proposed survey of UK merchants as part of its review of cross border interchange fee remedies. The survey...more
‘Anti-Copycatting’ Investigation Demonstrates Wide Range of Dominance Allegations and Benefits of Complaints- On 16 February 2026, the European Commission (EC) announced it closed an investigation into whether a medical...more
The decision clears a legal path for state-level regulation of credit and debit card swipe fees (while striking down data usage restrictions), setting the stage for a high-stakes appeal....more