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Insights and Expertise

If you're an issuer: holding that networks, not banks, set the fees, the court
• Model the revenue impact on your Illinois portfolio opened a path for state-level intervention that the industry
(particularly high-tax cities and restaurant/hospital- didn't think existed.
ity categories). Whether that path survives appeal is uncertain. But even
• Ensure systems can match late merchant tax docu- if Illinois loses on appeal, the July 1 implementation will
mentation to historical transactions. provide real-world data on whether the payment system
• Train operations teams on the 30-day reimburse- can adapt to state-by-state interchange rules. For an
ment requirement. industry built on standardization and network effects,
• Prepare customer communications if you adjust fees that's a stress test nobody wanted.
or benefits to offset revenue loss. The clock is ticking.

If you're a merchant:
• Verify your POS system can separately report tax An alumnus of the University of San Diego, School of Law, Arzumanyan
and gratuity in transaction data. has a proven track record of drafting, reviewing, revising and negoti-
ating an extensive array of commercial contracts, including vendor,
• If not, budget for upgrades or prepare to use the nondisclosure, employment, software-as-a-service, consulting and mar-
manual 180-day submission process. keting agreements. Leveraging his prior in-house counsel background,
• Understand that you won't see automatic savings: Arzumanyan has also carved out a unique niche within the electronic
you must transmit the data correctly. payments industry as his transactional expertise now encompasses
merchant processing, merchant banking and sponsorship, referral, inde-
The bigger picture
pendent sales office, and other related agency agreements. Contact him
This decision fundamentally challenges the assumption at larzumanyan@glrlegal.com.
that interchange is untouchable by state regulation. By