May 27, 2025

Dear Senator:

We, the undersigned organizations, oppose efforts to impose price controls on credit cards. The inaccurately named Credit Card Competition Act has been filed as an amendment to the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act (S. 1582) – if included it would turn the GENIUS Act into a Trojan Horse for credit card price controls. A separate amendment would use what should be a stablecoin bill to impose nationwide caps on credit card interest rates. Any distortive price controls on credit cards would be poison pills for the GENIUS Act that should be kept out.

The GENIUS Act aims to statutorily codify the rules of the road for payment stablecoin issuers in the United States. The bill provides guidelines for federal and state regulation of payment stablecoins, including transparency requirements, rules to combat money laundering, and safeguards to ensure stable reserves. It would enable banks to issue their own stablecoins pegged to the U.S. dollar, facilitating frictionless digital commerce.

However, any attempt to insert provisions of the Durbin-Marshall Credit Card Competition Act into this bill would turn it into a Trojan Horse for credit card price controls.

CCA would also harm small financial institutions. According to a recent study, the CCCA “would significantly reduce revenue for community banks and credit unions and – concomitantly – reduce access to credit in smaller markets across the United States, disproportionately affecting low-income households.” Including the CCCA in the GENIUS Act would contravene its purported goal, which is to increase access to financial services.

The Credit Card Competition Act remains a bad idea that would threaten rewards programs and network security. It would amount to government price-fixing that disrupts preexisting commercial contracts between card networks, banks, and merchants, and it would ultimately disadvantage smaller merchants over big box stores with the market power to negotiate favorable terms with card networks that mom-and-pop stores lack.

Senator Hawley has also filed an amendment to impose price controls on credit cards, which will only make it harder for working Americans to access credit. Congress already recognized that rate caps are distortive. Prior to 1980, the Federal Reserve’s Regulation Q imposed interest rate caps on bank deposit accounts. Regulation Q was gradually phased out between 1980 and 1986. According to a document published by the Federal Reserve Bank of St. Louis, “Congress concluded that interest rate ceilings created problems for depository institutions, discriminated against small savers, and did not increase the supply of residential mortgage credit.”

Credit card price controls are not germane to the GENIUS Act would undermine its goals by empowering the Federal Reserve to indefinitely control credit card interchange fees and creating an artificial shortage of credit.

To ensure successful stablecoin legislation and prevent harmful credit card price controls, we urge you to vote against the inclusion of any provisions of the Durbin-Marshall credit card price control bill in the amended GENIUS Act.

Sincerely,

Grover Norquist
President, Americans for Tax Reform

Tom Schatz
President, Council for Citizens Against Government Waste

Steve Pociask
Chief Executive Officer, American Consumer Institute

James Erwin
Interim Director, Shareholder Advocacy Forum

Phil Kerpen
President, American Commitment

Daniel Erspamer
Chief Executive Officer, Pelican Institute for Public Policy

Karen Kerrigan
Policy President & CEO, Small Business & Entrepreneurship Council

Brent Gardner
Chief Government Affairs Officer, Americans for Prosperity

Brandon Arnold
President, National Taxpayers Union

Yaël Ossowski
Deputy Director, Consumer Choice Center

Lisa B. Nelson
Chief Executive Officer, ALEC Action

John Berlau
Director of Finance Policy, Competitive Enterprise Institute

David Williams
President, Taxpayers Protection Alliance

Paul Gessing
President, Rio Grande Foundation

Caroline Melear
Resident Fellow, R Street Institute

Lorenzo Montanari
Executive Director, Property Rights Alliance

Ryan Ellis
President, Center for a Free Economy

Gerard Scimeca
Chairman, Consumer Action for a Strong Economy

David Guenthner
Vice President of Government Affairs, Mackinac Center for Public Policy

Chris Cargill
President, Mountain States Policy Center

Stefan J. Padfield
Executive Director, Free Enterprise Project, National Center for Public Policy Research

James R. Copland (individual signer)
Senior Fellow and Director, Legal Policy, Manhattan Institute