Congress quietly narrows credit card competition to protect big networks
S. 3623 — Credit Card Competition Act of 2026 · Filed by Roger Marshall (R-KS) · 5 cosponsors · Introduced Jan 13, 2026 · Referred to committee
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What it does
This bill requires large credit card issuers (those with over $100 billion in assets) and payment networks to stop forcing merchants and cardholders to use only one or two specific payment networks. Instead, merchants must be allowed to route credit card transactions through any available network, and card issuers cannot penalize merchants for choosing cheaper or faster networks. The bill exempts networks deemed national security risks and three-party systems (like American Express), and gives the Federal Reserve one year to write the rules.
Why we flagged it
The bill's core function is to mandate competition in credit card routing by prohibiting exclusive network agreements and routing restrictions. It is fundamentally a deregulation measure that removes contractual barriers between networks and merchants, framed as pro-competition but with significant carve-outs.
What the text implies
- The $100 billion asset threshold exempts most regional and mid-size card issuers, potentially creating a two-tier system where only the largest players face routing competition, limiting the bill's competitive reach.
- The national security carve-out allows the Federal Reserve to exempt foreign payment networks from routing requirements without transparent criteria, potentially protecting domestic networks from international competition.
- Three-party system exemption (e.g., American Express) preserves closed-loop networks' ability to restrict routing, creating a competitive advantage for issuers that own their own networks versus those that license them.
- Merchants may gain routing choice but lack incentive to pass fee savings to consumers; the bill does not mandate fee transparency or require merchants to disclose savings, so competitive benefits may accrue only to merchants.
- The 180-day implementation timeline after Federal Reserve rulemaking (1 year to write rules + 180 days to implement) creates a 18-month lag before any competitive effects materialize, during which networks may restructure contracts to circumvent intent.
Who it affects
Merchants and potentially consumers could benefit from lower processing fees and faster transactions through network competition, but the bill's narrow scope (only large issuers, exemptions for security/three-party systems) limits its reach. The actual consumer benefit depends on whether merchants pass savings along rather than pocket them.
Who stands to gain
- Merchants and payment processors (lower routing fees)
- Smaller payment networks (access to larger issuer networks)
- Fintech payment platforms (routing flexibility)
Named in the bill
Federal Reserve Board, Secretary of the Treasury, Mastercard (MA), Visa (implied, largest network), American Express (three-party exemption), Discover (three-party exemption), Electronic Fund Transfer Act (15 U.S.C. 1693o–2), Truth in Lending Act (section 103), Large card issuers (>$100B assets), Payment card networks, Merchants and acquirers
Where it stands
5 cosponsors: 2 Democrats, 2 Republicans, 1 Independents.
- Jan 13, 2026 — Introduced · Congress.gov: “Introduced in Senate”
- Jan 13, 2026 — Referred to Senate Committee on Banking, Housing, and Urban Affairs · Congress.gov: “Read twice and referred to the Committee on Banking, Housing, and Urban Affairs”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
49 lobbying clients named this bill on 51 disclosure filings across 2 quarters, Dec 2025 to Jun 2026. Those filings disclosed $23,844,000 in lobbying spend. A filing names 6 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 99% of bills with at least one filing.
Roger Marshall, the sponsor, reported $1,777,391 in PAC receipts in the 2026 cycle. $33,000 of that came from 5 PACs tied to these lobbying clients.
- Amazon.com Services LLC — $4,360,000 on 1 filing
- American Bankers Association — $3,510,000 on 1 filing
- Boeing Company — $2,770,000 on 1 filing
- Visa, Inc. — $2,150,000 on 1 filing
- Mastercard Worldwide — $1,610,000 on 1 filing
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the full bill text on Jun 8, 2026; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.
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