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Financial Services Industry Interchange Fees Federal Reserve

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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

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

ABA and State Bankers Associations ask Federal Reserve to withdraw its debit card interchange proposed rule

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The American Bankers Association (ABA) along with 50 state bankers associations, the DC Bankers Association and Puerto Rico Bankers Association sent a letter (the “ABA Letter”) to the Federal Reserve “in strong opposition to...more

Ballard Spahr LLP

Senator Durbin attempts to revive Durbin 2.0 with Senate Judiciary Committee hearing in April and solicits testimony from Visa,...

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On April 9, 2024, the Senate Judiciary Committee will hold a hearing on credit card competition. Senator Dick Durbin (D-IL) requested testimony at the hearing from the following Chief Executive Officers who have publicly...more

Ballard Spahr LLP

Federal Reserve extends comment period for debit card interchange fee rulemaking

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The Board of Governors of the Federal Reserve (the “Board”) has announced that it is extending the comment period for its proposed changes to its debit card interchange fee rule until May 12, 2024. Comments were originally...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: Understanding the Federal Reserve Board Proposal to Lower Interchange Fee Cap for Debit...

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Our special guest is Zarik Khan, Founder of Finsolute Advisors. In October 2023, the Federal Reserve Board issued a proposal to lower the maximum interchange fee that a large debit card issuer can receive for a debit card...more

Ballard Spahr LLP

Durbin 2.0 Congressional Research Service Report Indicates Uncertainty of Routing Restrictions Impacts on Industry

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On December 13, 2023, the Congressional Research Service issued a report titled How the Credit Card Competition Act of 2023 Could Affect Consumers, Merchants, and Banks highlighting potential issues for Congress....more

Latham & Watkins LLP

FRB Proposes to Lower Debit Card Interchange Fee

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A proposed rule would lower the maximum amount that large debit card issuers can charge merchants for each transaction. On October 25, 2023, the Board of Governors of the Federal Reserve System (FRB) published a proposal...more

Cadwalader, Wickersham & Taft LLP

A Further Look at the FRB’s Debit Interchange Cap Proposal

As we mentioned last week, the Federal Reserve Board (“FRB”) announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the...more

Ballard Spahr LLP

Federal Reserve Considering Lowering Debit Card Interchange Fee Caps (UPDATED)

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As we previously blogged, the Board of Governors of the Federal Reserve (the “Board”) held an open meeting on October 25, 2023 to discuss the debit card interchange fee cap. The debit card interchange fee cap was part of the...more

Wilson Sonsini Goodrich & Rosati

The Fed Proposes a Sea Change in Debit Card Interchange Fee Regulation

The Federal Reserve Board has proposed a new rule for public comment that would significantly lower the cap on interchange fees that debit card issuing banks (issuers) may charge a merchant’s bank (an acquiring bank) for...more

Cadwalader, Wickersham & Taft LLP

Federal Reserve Board Proposes Adjusting Debit Interchange Caps in Accordance with the Durbin Amendment

The Federal Reserve Board announced proposed changes to Regulation II (Debit Card Interchange Fees and Routing), which is the implementing regulation of the Durbin Amendment to the Dodd-Frank Act....more

Ballard Spahr LLP

Federal Reserve considering revisions to debit card interchange fees

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The Board of Governors of the Federal Reserve (FRB) is holding an open meeting on October 25, 2023 to discuss proposed revisions to the Board’s debit interchange fee cap contained in Regulation II, which implemented the...more

Ballard Spahr LLP

SCOTUS to Determine When Clock Starts under APA’s Statute of Limitations

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Last Friday, the U.S. Supreme Court agreed to decide when a right of action first accrues for an Administrative Procedure Act (APA) challenge to a final rule issued by a federal agency—when the final rule is issued or when...more

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