As a follow-up to last week’s update regarding the Illinois Interchange Fee Prohibition Act (IFPA), recent actions by both the Office of the Comptroller of the Currency (OCC) and the National Credit Union Administration (NCUA) have added momentum toward potentially limiting or delaying implementation of the law.
However, the IFPA remains in effect pending ongoing litigation, and significant legal, operational, and compliance uncertainty continues — particularly for state-chartered credit unions whose members may conduct transactions in Illinois.
In light of these developments, Velera has issued a member communication and provided sample comment letter templates for credit unions to use and distribute. As litigation proceeds and additional appeals are anticipated, the broader credit union system — including California’s and Nevada’s Credit Unions — continues actively engaging on the issue.
At the same time, the operational and financial implications of the IFPA remain substantial, including complex transaction-level compliance requirements, processor and network readiness concerns, operational burdens, and potentially significant penalties for noncompliance. Given the potential impact on interstate payment activity and the broader payments ecosystem, continued industry engagement remains critical.
The California and Nevada leagues strongly encourage credit unions to submit comment letters to the OCC by May 29 in support of the agency’s position regarding federal preemption and the need for a consistent national payments framework. Please utilize the following:
California’s and Nevada’s Credit Unions will continue coordinating with system partners and monitoring developments related to interchange regulation, payments policy, and the ongoing litigation.
Questions may be directed to Lisa Quaranta, Vice President of Regulatory Advocacy for the California and Nevada leagues.
