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IBA Files Principal Brief in Appeal of Interchange Decision. The Illinois Bankers Association and its co-plaintiffs have filed their principal brief with the U.S. Court of Appeals for the Seventh Circuit, arguing that the Northen District of Illinois erred in denying in part the plaintiffs’ motion for a permanent injunction against enforcement of the Illinois Interchange Fee Prohibition Act (IFPA). Plaintiffs contend that the IFPA’s interchange fee prohibition and data usage limitation provisions are preempted by federal law and request that the Seventh Circuit reverse the district court’s decision and instruct it to permanently enjoin “both IFPA components against banks, savings associations or savings banks, and credit unions chartered by the federal government or states other than Illinois, as well as against other payment-system participants.” Read the IBA’s Principal Brief of Plaintiffs-Appellants-Cross-Appellees.
March 18, 2026
OCC and Former Comptrollers Support IBA’s Appeal of Interchange Decision. The OCC and a coalition of former OCC Comptrollers and Acting Comptrollers have filed amicus briefs in support of the Illinois Bankers Association’s appeal of a federal district court decision to uphold in part the Interchange Fee Prohibition Act (IFPA). The briefs argue that the appeal’s outcome has “serious implications for national bank powers” and warn that failure to enjoin the IFPA “may well trigger a cascade of similar state and local laws that would give rise to a fractured, highly inefficient, and unworkable nationwide payment system—defeating a core promise of the federal banking system in this country.” Read the OCC
and former comptroller amicus briefs.
March 18, 2026
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