The Progressive Policy Institute (PPI), based in Washington, D.C., is a catalyst for policy innovation and political reform. Its mission is to create radically pragmatic ideas for moving the United States beyond ideological and partisan deadlock.
The Board of Governors for the Federal Reserve System and the Proposed Intervenors analyze the Durbin Amendment, using its text and other tools of statutory interpretation, to show that the Board complied with the congressional intent and the Administrative Procedures Act when crafting the interchange fee standard in Regulation II. Amicus endorses but does not replicate that analysis. Instead, consistent with PPI’s mission and expertise, this brief focuses on the broad economic and security harms that would result from adopting Appellant’s position.
