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 Comment Letters

OCC Action Could Preserve a Uniform National Payments System

5/31/2026

 
The payments industry is closely watching a recent proposal from the Office of the Comptroller of the Currency (OCC) that could have significant implications for banks, payment providers, merchants, and consumers nationwide. The OCC has proposed clarifying that national banks and federal savings associations retain the authority to assess non-interest charges and fees, including interchange fees, and that certain provisions of Illinois' Interchange Fee Prohibition Act (IFPA) are preempted by federal law.

The Innovative Payments Association (IPA) recently submitted comments supporting the OCC's proposals, highlighting concerns that state-level restrictions on interchange fees and payment data usage could create operational challenges across the payments ecosystem. The association noted that many modern financial products and services rely on a seamless, nationwide payments infrastructure supported by consistent regulatory standards.
​
Beyond Illinois, similar legislative efforts are emerging in other states, raising broader questions about how the U.S. payments system can continue to operate efficiently if differing state requirements begin to govern core payment functions. A fragmented regulatory framework could increase complexity for financial institutions and payment providers while potentially impacting the products and services consumers rely on every day.

The IPA believes the OCC's action provides important clarity for the industry and helps maintain the uniform national framework that supports secure, reliable, and widely accepted electronic payments. As policymakers continue to debate the future of interchange regulation, these issues will remain critical to the stability and efficiency of the payments ecosystem.

For additional details and the IPA's full analysis, download and read the complete comment letter.
Download Comment Letter

Securing the Future of Fintech: Why the IPA is Backing the Latest AI Legislation

5/26/2026

 
The Innovative Payments Association (IPA) is voicing support for H.R. 4801, the Unleashing AI Innovation in Financial Services Act, legislation aimed at giving financial services companies more room to responsibly test and implement artificial intelligence technologies. In a letter sent to House Financial Services Committee Chairman French Hill, the IPA emphasized that AI is already playing a valuable role across the payments ecosystem, particularly in areas like fraud prevention and operational efficiency.

According to the letter, the bill would create a framework that allows companies to work directly with federal regulators while experimenting with new AI-driven products and services. The IPA argues this approach would help strike the right balance between innovation, consumer protection, and safety and soundness standards across the financial system.

The association also noted that the legislation aligns with broader national efforts to accelerate responsible AI adoption in the United States. As policymakers and regulators continue debating the future of AI oversight, proposals like H.R. 4801 could shape how emerging technologies are integrated into banking, payments, and fintech innovation in the years ahead.

The IPA’s message underscores a growing industry view that collaboration between regulators and innovators will be essential as AI capabilities evolve. The organization encouraged lawmakers to advance the bill and continue supporting policies that foster innovation while maintaining strong consumer protections.
For more information and to read the full letter, download the IPA’s official submission to the House Financial Services Committee.
Download the Comment Letter

IPA Supports Legislation to Advance Responsible AI Innovation in Financial Services

4/23/2026

 
As artificial intelligence continues to reshape the financial services landscape, policymakers are increasingly focused on how to foster innovation while maintaining strong consumer protections. In a recent comment letter to the House Financial Services Committee, the Innovative Payments Association (IPA) expressed its support for H.R. 4801, the Unleashing AI Innovation in Financial Services Act.

The letter highlights how AI is already playing a meaningful role across the industry, particularly in areas like fraud prevention, and underscores the significant potential for future applications. As new technologies emerge, financial institutions are looking for clear pathways to responsibly test and deploy these tools without facing unnecessary regulatory barriers.

H.R. 4801 aims to strike that balance by creating a framework that allows companies to experiment with AI in coordination with key federal regulators. By enabling collaboration with agencies such as the FDIC, OCC, and CFPB, the legislation would support innovation while maintaining appropriate oversight and safeguards.

The IPA emphasizes that thoughtful integration of AI can strengthen the financial ecosystem, which enhances services, improving security, and delivering better outcomes for consumers. The association encourages lawmakers to advance the bill as part of a broader effort to ensure the U.S. remains competitive in the global AI landscape.
Download Comment Letter

IPA Submits Comments to the Federal Reserve on the Future of Check Infrastructure

3/10/2026

 
The Innovative Payments Association (IPA) recently submitted a comment letter to the Federal Reserve in response to its Request for Information on the future of the Federal Reserve Banks’ check services. As policymakers consider how the payments system should evolve, the IPA emphasized the importance of prioritizing secure, efficient electronic payment options over continued reliance on paper checks.

In the letter, the IPA notes that electronic payment methods, including prepaid accounts, mobile wallets, and other digital payment products, offer stronger consumer protections and greater efficiency than traditional paper checks. These products are typically governed by federal consumer protection rules, provide error resolution and limited liability protections, and operate within regulated banking and anti-money laundering frameworks.

The IPA also highlighted the role electronic payments play in expanding financial access. Government agencies increasingly use digital and prepaid payment options to distribute benefits such as Social Security, unemployment insurance, and tax refunds. These tools help reach unbanked and underbanked consumers while reducing administrative costs and fraud risks associated with mailed checks.

​As the Federal Reserve evaluates the future of its check services, the IPA urged the Board to carefully consider the benefits of modern electronic payment systems and to conduct a transparent review of how payment infrastructure should evolve.
Download Comment Letter to Learn More

IPA Urges OCC to Modernize Regulation E for Prepaid Accounts

2/10/2026

 
The Innovative Payments Association (IPA) recently submitted a comment letter to the Office of the Comptroller of the Currency (OCC) in response to its request for input on Reg E requirements for prepaid accounts. The letter reflects IPA members’ view that the current Prepaid Rule has not kept pace with how consumers use prepaid products and mobile financial tools today.

Prepaid accounts, including prepaid cards, mobile wallets, and peer-to-peer payment products, have become primary financial tools for millions of Americans. However, key aspects of the rule were developed before widespread mobile banking adoption and now impose compliance obligations that are often duplicative, outdated, and confusing for both providers and consumers.

In its comments, the IPA outlines targeted recommendations to modernize the regulation while maintaining strong consumer protections. These include streamlining disclosure requirements, revisiting rigid electronic disclosure formatting standards, and aligning prepaid account obligations more closely with those that apply to credit cards and traditional deposit accounts.

The IPA believes thoughtful modernization of the Prepaid Rule would reduce unnecessary regulatory burden, support innovation, and better reflect how consumers interact with financial services today -- without weakening Reg E’s core protections.

For a detailed discussion of IPA’s recommendations and policy rationale, download the full comment letter.
Download Comment Letter
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