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IBA Submits New Filing in Interchange Law Appeal. The Illinois Bankers Association and its co-plaintiffs have filed a response and reply brief in support of the appeal in our litigation challenging the Interchange Fee Prohibition Act (IFPA). The brief argues that the IFPA is preempted by federal law — the position taken by the OCC in its amicus brief — and that the law will “upend the debit- and credit-card operations of federally chartered financial institutions and wreak havoc on the national payment-processing system.” Oral arguments remain scheduled for May 13, 2026, at 2:00 p.m. Central Time. Read the IBA’s Response and Reply Brief.
April 20, 2026
Banking Agencies Revise Model Risk Management Guidance. The OCC, Federal Reserve, and FDIC have issued revised model risk management guidance establishing a risk-based approach to model risk management, tailored to a bank’s risk profile and the size and complexity of its operations. The guidance generally does not apply to banks with $30 billion or less in total assets. Read the announcement, guidance, OCC Bulletin 2026-13, Fed SR 26-2, and FDIC FIL-15-2026.
April 20, 2026
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