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The OCC argues that the IFPA is an “ill-conceived, highly unusual, and largely unworkable state law that threatens to fragment and disrupt” the nation-wide payments system. Further, the OCC states that “the IFPA constitutes both bad policy and an unlawful interference with federally granted powers.” Read the OCC amicus brief and the IBA’s Memorandum in Support of Motion for a Preliminary Injunction.