ifpa

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On June 1, 2026, Chief Judge Virginia Kendall of the U.S. District Court for the Northern District of Illinois issued a major follow-up opinion in Illinois Bankers Association v. Raoul that substantially alters the court’s February 2026 summary judgment decision regarding the Illinois Interchange Fee Prohibition Act (“IFPA”).

The new opinion was issued after the Seventh Circuit vacated the district court’s February ruling and remanded the case for reconsideration in light of the Office of the Comptroller of the Currency’s April 2026 Interim Final Rule and Interim Final Order addressing the IFPA.… Continue Reading

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 court’s judgment and remanding the case for further proceedings in light of the OCC’s recently issued Interim Final Rule and preemption order.… Continue Reading

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 with Corner Post in holding that a Section 702 claim under the Administrative Procedure Act (APA) to challenge a final agency action first accrues when the plaintiff is injured by final agency action and has the right to assert it in court.… Continue Reading

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 Attorney General challenging the enactment of the Interchange Fee Prohibition Act (the “IFPA”). The 74 page complaint seeks a declaratory judgment that the IFPA is preempted by federal laws, unconstitutional, and invalid as applied to any participant in the payment system, and to permanently enjoin the state from taking any investigatory or enforcement actions under the IFPA.… Continue Reading