1. United States
2. Md.
3. Letter

The Credit Card Competition Act of 2023 aims to promote competition and choice in the credit card transaction market. However, the regulations it proposes could have unintended consequences that undermine innovation, cybersecurity, and consumer protections. I urge caution in moving forward with this legislation. The requirement for card issuers to enable routing over any payment network raises security concerns. Payment networks have different security standards and technologies. Forcing interoperability could create vulnerabilities that put consumers at risk of fraud and data breaches. Additionally, networks designated national security risks by the government would be exempt, creating an uneven playing field. The market share provision arbitrarily limits routing options to the two largest networks after three years. This static rule fails to account for future market dynamics and emerging players. It institutionalizes a duopoly rather than fostering true competition and consumer choice over time. Rather than prescriptive routing mandates, a better approach would be principles-based regulation that protects network competition while prioritizing security, allowing networks to compete on service quality and innovate responsibly. I encourage a review of unintended consequences to consumers and an exploration of alternative pro-competition policies before advancing this legislation.