For years, the Defense Credit Union Council (DCUC) has raised concerns over the potential dangers of legislation like the Credit Card Competition Act (CCCA), warning that this legislation and similar proposals could undermine key defense-related policies while simultaneously enriching the largest multinational retailers at the expense of military and veteran consumers. The impacts of this legislation could ripple far beyond credit card payments—affecting the very foundations of consumer choice, financial security, and even national defense.
The CCCA, first introduced in 2022 and again in 2023, aims to overhaul how credit card transactions are processed by requiring that certain transactions be routed through cheaper, less secure networks. Initially framed as a win for consumers, proponents claim that this will lower prices by forcing credit card networks to compete on cost. The everyday consumer, especially military families and low-income Americans, will bear the brunt of higher costs and reduced services.
DCUC has consistently argued that any CCCA-like amendments pose a direct threat to the security, reliability, and competitiveness of the nation’s payment system. In 2022, DCUC detailed these concerns in a letter to the Senate, referencing a 2014 survey from the Federal Reserve Bank of Richmond to highlight how similar regulatory changes, like the 2010 Durbin Amendment, resulted in higher prices and restricted access to debit card services. The survey found that merchants simply raised prices or imposed debit card usage restrictions to circumvent interchange fees, doing little to benefit the consumer.
Despite these warnings, Senators Dick Durbin (D-IL) and Roger Marshall (R-KS) have continued to push for amendments to the National Defense Authorization Act (NDAA) that would introduce CCCA-like provisions into must-pass legislation, such as H.R. 3881 and H.R. 4366.
DCUC immediately responded by sending repeated letters, some jointly signed by fellow industry associations and partners including the Credit Union National Association (CUNA), National Association of Federally Insured Credit Unions (NAFCU), Electronic Payments (EPC), and military or veteran associations including the Veteran of Foreign Wars (VFW), Veterans Administration (VA), to key committees in both chambers of Congress, emphasizing how these amendments would harm consumers, community banks, and credit unions, while benefiting multinational retailers with deep pockets.
DCUC’s opposition has remained a simple yet critical point: the proposed amendments would force consumers to abandon their preferred payment networks in favor of cheaper, less secure alternatives. Credit cards are not just a means of payment—they are a tool for consumer protection and financial empowerment. They come with consumer benefits like fraud protection, security features, and rewards programs that help working families stretch their budgets. By pushing through these amendments, retailers would be permitted to route transactions through the cheapest network available to them, undermining consumer trust and security in the process.
In addition to the immediate impact on consumers, the long-term consequences for credit unions and community banks would be severe. DCUC President/CEO, Anthony Hernandez, has stressed for years that smaller financial institutions would face billions in costs to update their systems to accommodate these changes, costs they would likely have to pass on to their customers while leaving fewer choices for consumers, particularly in underserved areas.
The reality is that the CCCA is not about helping consumers—it’s about consolidating power in the hands of large retailers, who stand to gain billions of dollars by routing transactions through cheaper, less secure networks. This would not only reduce consumer benefits but also put consumers' data at greater risk, as these alternative networks have historically underinvested in security.
In recent letters, DCUC emphasized how merchants are falsely claiming that the CCCA will lower prices for consumers. DCUC emphasized to Congress how this argument echoes the rhetoric used by big box retailers during the debate over the 2010 Durbin Amendment, which promised lower costs but resulted in higher profits for corporations and higher fees for consumers. The legislation would have the same effect: padding the bottom line of the nation’s largest retailers while hurting consumers, particularly lower-income individuals, as well as military and veteran communities.
Fortunately, Congress listened to the concerns of DCUC and did not include the CCCA in the FY 2025 NDAA or other must-pass legislation. This result is a huge win for military families as 2024 comes to a close.
DCUC’s successful efforts to push back against attempts to pass the CCCA have been relentless, and for good reason. These are not just issues of economic policy—they are also matters of national security. When military families and veterans are forced to pay higher banking fees or lose access to preferred financial services, it weakens the financial stability of one of the nation’s most vulnerable populations. By undermining the private-sector payments system, these amendments could leave the door open for greater federal control and micromanagement of the financial services industry, an approach that could have far-reaching consequences for both consumers and national security.
It’s clear that the CCCA is not in the best interest of American consumers, particularly the men and women who serve in our armed forces. But the fight is not over. As we begin a new Congress with new lawmakers in 2025, DCUC will continue to advocate for and elevate policies to key legislators that prioritize consumer security and the financial well-being of military families and veterans.
