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Payment Systems Regulatory Reform

A&O Shearman

ECB Decision (EU) 2025/1148 on access by Non-Bank Payment Service Providers to TARGET published in OJ

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The Decision (EU) 2025/1148 of the European Central Bank (ECB) adopted on 2 June, has been published in the Official Journal of the European Union. This decision amends Decision (EU) 2025/222 concerning access by non-bank...more

A&O Shearman

EBA opinion on PSD2 and MiCAR

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The European Banking Authority (EBA) has issued an opinion (referred to as the No Action letter) in response to a request from the European Commission (EC) in December 2024, on the interplay between Payment Services Directive...more

A&O Shearman

ECB consults on extension to T2 operating hours

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The European Central Bank (ECB) has published a consultation paper (CP) exploring the extension of operating hours for its real-time gross settlement (RTGS) system, T2. This involves both its daily operational hours and its...more

Morgan Lewis

E-Money Tokens: European Banking Authority Clarifies PSD2-MiCA Interplay – Implications for CASPs

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Barely a year after the entry into application of MiCA, the European Banking Authority published a "No-Action Letter" aimed at securing the applicable regime for cryptoasset service providers operating in relation to e-money...more

Sheppard Mullin Richter & Hampton LLP

Illinois Delays Interchange Fee Ban by One Year

On June 1, the Illinois General Assembly passed a bill that, if enacted, will delay the effective date of the Interchange Fee Prohibition Act by one year, from July 1, 2025, to July 1, 2026. The law prohibits financial...more

Orrick, Herrington & Sutcliffe LLP

Illinois amendment to delay the effective date of its Interchange Fee Prohibition Act passes both chambers

On May 31, the Illinois General Assembly passed legislation to defer the effective date of the Interchange Fee Prohibition Act by one year until July 1, 2026. As previously covered by InfoBytes, Illinois originally enacted...more

Bass, Berry & Sims PLC

Bedlam No More: Oklahoma Formally Allows Credit Card Surcharges

On May 28, Oklahoma enacted SB 677, which became law without the signature of Oklahoma Governor Kevin Stitt. This new law repeals Oklahoma Statute Title 14A, Section 2-417, which previously barred sellers from imposing a...more

Ropes & Gray LLP

FCA Extends Investment Research Payment Optionality to Fund Managers

Ropes & Gray LLP on

Last month the Financial Conduct Authority (FCA) set out its final rules related to the application of investment research payment optionality to fund managers. This move follows its consultation paper late last year which...more

Orrick, Herrington & Sutcliffe LLP

Washington State enacts provisions to allow companies to deduct interchange fees

On May 20, the governor of Washington State signed into law HB 2020 which amends the state’s tax laws to exclude interchange fees from the business and occupation tax. The legislation stemmed from a lawsuit where a company...more

Blake, Cassels & Graydon LLP

Aperçu de l’évolution de la réglementation dans le secteur canadien des paiements en 2025

Les modifications réglementaires apportées à l’écosystème canadien des paiements redéfinissent le risque opérationnel, les obligations en matière de conformité et les modalités commerciales dans l’ensemble du secteur....more

A&O Shearman

UK Government advances BNPL Regulation

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HM Treasury (HMT) has published a response to its 2024 consultation on regulating Buy-Now, Pay-Later (BNPL) products and laid the draft secondary legislation (Financial Services and Markets Act 2000 (Regulated Activities etc)...more

McDermott+

A Preview of the Preview: Our CY 2026 PFS Proposed Rule Webinar Is Next Wednesday

McDermott+ on

It’s getting hot outside, which means that the summer regulatory season is almost upon us. In June or July, the Centers for Medicare & Medicaid Services (CMS) will release proposed regs impacting Medicare payments in...more

A&O Shearman

Amendment to the TARGET Guideline postponed

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The European Central Bank (ECB) has announced that the amendment to the TARGET Guideline, which would allow non-bank payment service providers (non-bank PSPs) to participate in TARGET is postponed... ...more

A&O Shearman

PSR update on impact of APP fraud reimbursement scheme

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The UK Payment Systems Regulator (PSR) has published an update on what it has seen since the implementation of its authorised push payment (APP) fraud reimbursement scheme in October 2024. The data covers UK payments made via...more

Ballard Spahr LLP

Trump signs resolution voiding CFPB large nonbank supervision rule

Ballard Spahr LLP on

President Trump has signed a resolution nullifying the rule implementing the CFPB’s power to supervise large nonbank financial services providers of general-use digital consumer payment applications....more

Brownstein Hyatt Farber Schreck

Colorado Enacts the Model Money Transmission Act

On April 18, 2025, Colorado enacted the Model Money Transmission Modernization Act (MTMA) (HB 25-1201), which repeals and replaces the state’s previous Money Transmitters Act. The law updates standards for the licensing,...more

A&O Shearman

FCA policy statement on investment research payment optionality for fund managers

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The UK Financial Conduct Authority (FCA) has published a final policy statement (PS25/4), together with an updated webpage and press release, on final rules extending the new payment optionality for investment research to...more

Orrick, Herrington & Sutcliffe LLP

President Trump repeals two CFPB rules

On May 9, President Donald Trump repealed two CFPB rules which were brought under the previous administration. The first action repealed the CFPB’s overdraft lending rule (S. J. Res. 18), which would have capped overdraft...more

Orrick, Herrington & Sutcliffe LLP

CFPB withdraws EFT interpretive rule

On May 15, the CFPB published a Federal Register notice withdrawing its proposed interpretive rule on EFTs titled “Electronic Fund Transfers Through Accounts Established Primarily for Personal, Family, or Household Purposes...more

Ankura

An Update on the CSBS Money Transmission Modernization Act (MTMA)

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The financial landscape is rapidly evolving, with digital payment solutions becoming increasingly integral to both consumers and businesses. Amidst this shift, the Money Transmission Modernization Act (MTMA) emerged as a...more

K&L Gates LLP

United States: The Continuing Shift to Modern Money Transmission Laws

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Within the past two months, three states have adopted the Money Transmission Modernization Act (MTMA). The governors of Virginia, Mississippi, and most recently Colorado, signed bills that implement the MTMA, and two other...more

Blake, Cassels & Graydon LLP

The Shape of Things to Come: Regulatory Developments in Canadian Payments 2025

Regulatory updates to Canada’s payments ecosystem are reshaping operational risk, compliance obligations and commercial terms across the sector. From interest rate thresholds to anti-money laundering safeguards, there are...more

Walkers

The BMA invites feedback on proposed Payment Services Provider regulatory framework

Walkers on

The Bermuda Monetary Authority ("BMA") proposes a new Payments Services Act ("PSA") to replace the Money Service Business Act 2016 to establish a clear, risk-based framework for Payment Service Providers ("PSPs") operating in...more

Sheppard Mullin Richter & Hampton LLP

CMS Proposes Medicare Payment Policies for Hospital Inpatient Services for Federal Fiscal Year 2026

The Centers for Medicare & Medicaid Services (CMS) recently published the fiscal year (“FY”) 2026 proposed rule for Hospital Inpatient Prospective Payment Systems (IPPS) (the “Proposed Rule”). Comments to the Proposed Rule...more

Sheppard Mullin Richter & Hampton LLP

Colorado Overhauls Money Transmission Law to Align with Multistate Licensing Standards 

On April 16, the Colorado General Assembly enacted House Bill 25-1201, replacing the state’s prior money transmitter law with the Money Transmission Modernization Act (the “Act”). Modeled on the multistate framework developed...more

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