[House Report 119-522]
[From the U.S. Government Publishing Office]


119th Congress    }                                      {      Report
                        HOUSE OF REPRESENTATIVES
 2d Session       }                                      {     119-522

======================================================================



 
                  PROTECTING PRIVACY IN PURCHASES ACT

                                _______
                                

 February 25, 2026.--Committed to the Committee of the Whole House on 
            the State of the Union and ordered to be printed

                                _______
                                

    Mr. Hill of Arkansas, from the Committee on Financial Services, 
                        submitted the following

                              R E P O R T

                             together with

                             MINORITY VIEWS

                        [To accompany H.R. 1181]

    The Committee on Financial Services, to whom was referred 
the bill (H.R. 1181) to prohibit payment card networks and 
covered entities from requiring the use of or assigning 
merchant category codes that distinguish a firearms retailer 
from general-merchandise retailer or sporting-goods retailer, 
and for other purposes, having considered the same, reports 
favorably thereon with an amendment and recommends that the 
bill as amended do pass.

                                CONTENTS

                                                                   Page
Purpose and Summary..............................................     3
Background and Need for Legislation..............................     3
Committee Consideration..........................................     4
Related Hearings.................................................     5
Committee Votes..................................................     6
Committee Oversight Findings.....................................     9
Performance Goals and Objectives.................................     9
Committee Cost Estimate..........................................     9
New Budget Authority and CBO Cost Estimate.......................     9
Unfunded Mandates Statement......................................     9
Earmark Statement................................................     9
Federal Advisory Committee Act Statement.........................    10
Applicability to the Legislative Branch..........................    10
Duplication of Federal Programs..................................    10
Section-by-Section Analysis of the Legislation...................    10
Changes in Existing Law Made by the Bill, as Reported............    11
Documents Included by Unanimous Consent..........................    12
Minority Views...................................................    15

    The amendment is as follows:
  Strike all after the enacting clause and insert the 
following:

SECTION 1. SHORT TITLE.

  This Act may be cited as the ``Protecting Privacy in Purchases Act''.

SEC. 2. DISTINGUISHING FIREARM RETAILERS PROHIBITED.

  (a) Prohibitions Relating to Merchant Category Codes.--
          (1) For payment card networks.--A payment card network may 
        not require--
                  (A) a firearms retailer to use a merchant category 
                code that--
                          (i) is used only or primarily for firearms 
                        retailers; or
                          (ii) identifies such retailer as engaged in 
                        the business of selling firearms, ammunition, 
                        accessories of firearms, or components of 
                        firearms; or
                  (B) a covered entity to assign a merchant category 
                code that is used only or primarily for firearms 
                retailers or that identifies a firearms retailer as 
                engaged in the business of selling firearms.
          (2) For covered entities.--A covered entity may not assign to 
        a firearms retailer any merchant category code that is used 
        only or primarily for firearms retailers or that identifies 
        such retailer as engaged in the business of selling firearms, 
        ammunition, accessories of firearms, or components of firearms.
  (b) Enforcement.--
          (1) In general.--The Attorney General shall enforce this 
        section and shall, not later than 90 days after the date of the 
        enactment of this section, establish a process for individuals, 
        including firearms retailers, to submit complaints relating to 
        alleged violations of this section.
          (2) Investigation.--The Attorney General shall investigate 
        any complaint received through the processes established by the 
        Attorney General under paragraph (1).
          (3) Written notice.--If the Attorney General determines, 
        after conducting an investigation under paragraph (2), that a 
        payment card network or covered entity has violated this 
        section, the Attorney General shall send a written notice of 
        such violation to such payment card network or covered entity 
        that requires the payment card network or covered entity to 
        remedy the violation not later than 30 days after the date on 
        which the payment card network or covered entity receives such 
        notice.
          (4) Injunction.--
                  (A) In general.--If a payment card network or covered 
                entity does not remedy a violation within 30 days of 
                receiving a written notice under paragraph (3), the 
                Attorney General may bring an action in Federal court 
                to enjoin the violating behavior.
                  (B) No private right of action.--This Act does not 
                create a private right of action.
  (c) Preemption.--
          (1)  In general.--Any law of a State or local government 
        regulating the assignment, use, or disclosure of merchant 
        category codes that are used only or primarily for firearms 
        retailers or that identifies a retailer as engaged in the 
        business of selling firearms, ammunition, accessories of 
        firearms, or components of firearms is hereby preempted.
          (2) Limitation.--Notwithstanding paragraph (1), nothing in 
        this Act may be construed to prevent a payment card network or 
        a covered entity from complying with any Federal, State, or 
        local law or regulations related to dispute processing, fraud, 
        compliance management, or protecting transaction integrity from 
        concerns related to illegal or suspicious activities, data 
        breaches, or cyber risks.
  (d) Report.--The Attorney General shall, each year, submit a report 
to the Congress that--
          (1) identifies the number of investigations undertaken by the 
        Attorney General under subsection (b);
          (2) includes a summary of such investigations and their 
        disposition; and
          (3) provides any available data and analysis that relates to 
        the effectiveness of this Act.
  (e) Definitions.--In this Act:
          (1) Ammunition.--The term ``ammunition'' has the meaning 
        given the term in section 921(a)(17)(A) of title 18, United 
        States Code.
          (2) Covered entity.--The term ``covered entity'' means any 
        entity that--
                  (A) has on the date of the enactment of this section, 
                or establishes after the date of the enactment of this 
                section, a relationship with a merchant for the 
                purposes of processing credit, debit, or prepaid 
                transactions; or
                  (B) has on the date of the enactment of this section, 
                or establishes after the date of the enactment of this 
                section, a relationship with an entity that establishes 
                a relationship with a merchant for the purposes of 
                processing credit transactions, debit transactions, or 
                prepaid transactions.
          (3) Firearm.--The term ``firearm'' means--
                  (A) a ``firearm'' as such term is defined in section 
                921(a)(3) of title 18, United States Code;
                  (B) a ``shotgun'' as such term is defined in section 
                921(a)(5) of title 18, United States Code;
                  (C) a ``rifle'' as such term is defined in section 
                921(a)(7) of title 18, United States Code;
                  (D) an ``antique firearm'' as such term is defined in 
                section 921(a)(16) of title 18, United States Code;
                  (E) a ``semiautomatic rifle'' as such term is defined 
                in section 921(a)(29) of title 18, United States Code; 
                and
                  (F) a ``handgun'' as such term is defined in section 
                921(a)(30) of title 18, United States Code.
          (4) Firearms retailer.--The term ``firearms retailer'' means 
        a person, entity, or retail location physically located in the 
        United States that is engaged in the business of selling or 
        trading--
                  (A) firearms;
                  (B) ammunition;
                  (C) accessories of firearms; or
                  (D) components of firearms.
          (5) Merchant category code.--The term ``merchant category 
        code'' means a multi-digit code, issued by the International 
        Organization for Standardization, for the purposes of enabling 
        the classification of merchants into specific categories based 
        on the type of business, trade, or services supplied.
          (6) Payment card network.--The term ``payment card network'' 
        means an entity that directly or through a network participant, 
        processor, or agent provides proprietary services, 
        infrastructure, software, or hardware used to authorize, clear 
        and settle credit, debit, or prepaid transactions.

                          PURPOSE AND SUMMARY

    H.R. 1181, the Protecting Privacy in Purchases Act, was 
introduced on February 11, 2025, by Republican Representative 
Riley Moore (WV-02). This bill prohibits payment card networks 
from requiring the use of or assigning Merchant Category Codes 
(MCCs) that distinguish a firearms retailer from general 
merchandise or sporting-goods retailers.

                  BACKGROUND AND NEED FOR LEGISLATION

    As evidenced in Operation Choke Point under President Obama 
and Operation Choke Point 2.0 under President Biden, law-
abiding Americans have been victims of government encroachment 
on their financial privacy. Federal banking agencies have 
increasingly pressured financial institutions and payment 
processors to monitor or restrict lawful transactions based on 
political or reputational considerations. This coordination 
between regulators and private firms has raised legitimate 
concerns about the weaponization of the financial system 
against constitutionally protected behavior.
    H.R. 1181 establishes critical guardrails to ensure that 
Federal banking agencies do not coerce financial institutions 
or payment processors into surveilling, flagging, or debanking 
law-abiding customers.

                        COMMITTEE CONSIDERATION

                             119TH CONGRESS

    On February 11, 2025, Representative Moore (WV) introduced 
H.R. 1181, the Protecting Privacy in Purchases Act, with 
Representatives Andy Barr (R-KY), Richard Hudson (R-NC), Aaron 
Bean (R-FL), Ben Cline (R-VA), Scott Perry (R-PA), Beth Van 
Duyne (R-TX), Brett Guthrie (R-KY), Mike Collins (R-GA), Brad 
Finstad (R-MN), Barry Moore (R-AL), Daniel Webster (R-FL), 
Michael Guest (R-MS), Michael Rulli (R-OH), Roger Williams (R-
TX), Clay Higgins (R-LA), Mike Bost (R-IL), Claudia Tenney (R-
NY), Derek Schmidt (R-KS), Tim Moore (R-NC), Dan Newhouse (R-
WA), James Comer (R-KY), Steve Womack (R-AR), John Rose (R-TN), 
Rudy Yakym (R-IN), Brandon Gill (R-TX), and John Rutherford (R-
FL) as original cosponsors. Representatives Lauren Boebert (R-
CO), Mark Messmer (R-IN), Addison McDowell (R-NC), Andy Biggs 
(R-AZ), Darrell Issa (R-CA), Mark Green (R-TN), Jack Bergman 
(R-MI), Jodey Arrington (R-TX), Bill Huizenga (R-MI), Mike 
Kennedy (R-UT), Monica De La Cruz (R-TX), Joe Wilson (R-SC), 
Scott DesJarlais (R-TN), Andrew Clyde (R-GA), Nick LaLota (R-
NY), Sam Graves (R-MO), Mike Rogers (R-AL), Lance Gooden (R-
TX), David Kustoff (R-TN), Diana Harshbarger (R-TN), Nick 
Langworthy (R-NY), Mark Amodei (R-NV), Greg Murphy (R-NC), John 
Moolenaar (R-MI), Buddy Carter (R-GA), Austin Scott (R-GA), 
Derrick Van Orden (R-WI), Glenn Grothman (R-WI), David Valadao 
(R-CA), Bob Latta (R-OH), Randy Weber (R-TX), Troy Nehls (R-
TX), Ashley Hinson (R-IA), Tim Walberg (R-MI), Doug LaMalfa (R-
CA), David Rouzer (R-NC), Pete Sessions (R-TX), Andy Harris (R-
MD), Ann Wagner (R-MO), Gus Bilirakis (R-FL), Pete Stauber (R-
MN), Scott Franklin (R-FL), Tracey Mann (R-KS), Chuck Edwards 
(R-NC), Blake Moore (R-UT), Julia Letlow (R-LA), Ron Estes (R-
KS), Paul Gosar (R-AZ), Dale Strong (R-AL), Jefferson Shreve 
(R-IN), Randy Feenstra (R-IA), Adrian Smith (R-NE), Tom Tiffany 
(R-WI), Chuck Fleischmann (R-TN), Michael Cloud (R-TX), Jake 
Ellzey (R-TX), Scott Fitzgerald (R-WI), Robert Aderholt (R-AL), 
Kevin Hern (R-OK), August Pfluger (R-TX), Ryan Zinke (R-MT), 
Brian Babin (R-TX), Mike Ezell (R-MS), Don Bacon (R-NE), Max 
Miller (R-OH), Pat Harrigan (R-NC), John McGuire (R-VA), Tony 
Gonzales (R-TX), Trent Kelly (R-MS), Guy Reschenthaler (R-PA), 
Dan Crenshaw (R-TX), Jeff Hurd (R-CO), Craig Goldman (R-TX), 
Gabe Evans (R-CO), Brian Jack (R-GA), Barry Loudermilk (R-GA), 
Mark Harris (R-NC), Michael Baumgartner (R-WA), Pat Fallon (R-
TX), Elise Stefanik (R-NY), Jeff Van Drew (R-NJ), Mike 
Haridopolos (R-FL), Greg Steube (R-FL), Dan Meuser (R-PA), Mary 
Miller (R-IL), Lisa McClain (R-MI), William Timmons (R-SC), 
Wesley Hunt (R-TX), Troy Downing (R-MT), Tony Wied (R-WI), 
Julie Fedorchak (R-ND), Marlin Stutzman (R-IN), Abe Hamadeh (R-
AZ), Laurel Lee (R-FL), Nick Begich (R-AK), Russell Fry (R-SC), 
Ronny Jackson (R-TX), Sheri Biggs (R-SC), Dave Taylor (R-OH), 
Nathaniel Moran (R-TX), Michelle Fischbach (R-MN), Jimmy 
Patronis (R-FL), Zack Nunn (R-IA), Warren Davidson (R-OH) and 
Burgess Owens (R-UT) and David Joyce (R-OH) were added 
subsequently as cosponsors.
    The bill was referred solely to the Committee on Financial 
Services. H.R. 1181 was attached to the April 29, 2025, hearing 
titled ``Regulatory Overreach: The Price Tag on American 
Prosperity.''
    On December 16, 2025, the Committee on Financial Services 
met in open session to consider, among others, H.R. 1181. The 
Committee ordered H.R. 1181, as amended, to be reported with a 
favorable recommendation to the House of Representatives.

                             118TH CONGRESS

    On February 23, 2024, Representative Stefanik introduced 
H.R. 7450, the Protecting Privacy in Purchases Act, with 
Representatives Barr and Hudson as original cosponsors. 
Representatives Miller (IL), Bean, Walberg, Kat Cammack (R-FL), 
Guest, Hinson, Higgins, Moolenaar, Ralph Norman (R-SC), Mike 
Waltz (R-FL), James Baird (R-IN), Smith (NE), Grothman, Issa, 
Loudermilk, Moore (AL), Victoria Spartz (R-IN), Weber, 
Aderholt, LaLota, Bill Posey (R-FL), Green (TN), Fischbach, 
DesJarlais, Nehls, Hern, Fleischmann, Hunt, Austin Scott, Fry, 
Reschenthaler, Bilirakis, Rogers, Franklin, Tenney, Mann, Tony 
Gonzales, Yakym, Rutherford, Fallon, Babin, Cloud, Jerry Carl 
(R-AL), Collins, LaMalfa, Matt Rosendale (R-MT), Murphy (NC), 
Williams (TX), Harris (MD), Andrew Ogles (R-TN), Comer, 
Sessions, Rouzer, Ronny Jackson, Gooden, Amodei, Edwards, 
Carter, Jim Banks (R-IN), McClain, Stephanie Bice (R-OK), 
Perry, Finstad, Huizenga, Kelly, Pfluger, Wagner, Morgan 
Griffith (R-VA), Jeff Duncan (R-SC), Graves, John Joyce (R-PA), 
Boebert, Wilson, Feenstra, Guthrie, Steube, Stauber, Cline, 
Arrington, Womack, Miller (OH), Dan Bishop (R-NC), Clyde, Larry 
Bucshon (R-IN), John Curtis (R-UT), Debbie Lesko (R-AZ), 
Kustoff, Biggs (AZ), Gosar, Tiffany, Letlow, Brad Wenstrup (R-
OH), Neal Dunn (R-FL), Harshbarger, Langworthy, Robert Wittman 
(R-VA), Moore (UT), Crenshaw, Fitzgerald, Timmons, Erin Houchin 
(R-IN), Estes, Rose, Bergman, Dusty Johnson (R-SD), Mark Alford 
(R-MO), Cory Mills (R-FL), Lee, Bost, Van Duyne, De La Cruz, 
Zinke, Ezell, Kelly Armstrong (R-ND), Eric Burlison (R-MO), 
Strong, Ellzey, Newhouse, Valadao, Ken Calvert (R-CA), and 
Bacon were added subsequently as cosponsors. The bill was 
referred solely to the Committee on Financial Services.
    In addition, on April 8, 2024, Senator Bill Hagerty (R-TN) 
introduced S.4075, the Protecting Privacy in Purchases Act, a 
related bill to H.R. 7450. The bill was referred solely to the 
Committee on Banking, Housing, and Urban Affairs.
    There was no further legislative action on H.R. 7450 or 
S.4075 in the 118th Congress.

                            RELATED HEARINGS

    Pursuant to clause 3(c)(6) of rule XIII of the Rules of the 
House of Representatives, the following hearing was used to 
develop H.R. 1181:
    The Subcommittee on Financial Institutions held an April 
29, 2025, hearing titled, ``Regulatory Overreach: The Price Tag 
on American Prosperity.'' The Subcommittee heard testimony 
from: Ms. Sarah Flowers, Senior Vice President, Senior 
Associate General Counsel, Bank Policy Institute; Mr. J. 
Michael Radcliffe, Chairman and Chief Executive Officer, 
Community Financial Services Bank (Benton, KY); Mrs. Margaret 
E. Tahyar, Partner, Head of Financial Institutions Group, Davis 
Polk & Wardwell LLP; and the Honorable Graham Steele, Academic 
Fellow, Rock Center for Corporate Governance, Stanford Law 
School.

                            COMMITTEE VOTES

    Clause 3(b) of rule XIII of the Rules of the House of 
Representatives requires the Committee Report to include record 
votes on the motion to report legislation and amendments 
thereto.
    On December 16, 2025, the Committee ordered H.R. 1181, as 
amended, to be reported favorably to the House by a recorded 
vote of 29 yeas and 23 nays, a quorum being present. (Record 
Vote No. FC-218).
    The Committee considered the following amendments to H.R. 
1181:
           Representative Loudermilk offered an 
        amendment in the nature of a substitute, designated 
        MOOREWV_037, which made minor edits and technical 
        changes. This amendment was adopted by a voice vote.
           Representative Sam Liccardo (D-CA) offered 
        an amendment (No. 3), designated LICCAR_078. This 
        amendment would limit the bill's exception on the 
        assignment and use of Merchant Category Codes if use is 
        mandated under state law. The amendment also strikes 
        the bill's provision on federal pre-emption. This 
        amendment was defeated by a recorded vote of 23 yeas 
        and 29 nays, a quorum being present. (Record Vote No. 
        FC-217).

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]
        
                      COMMITTEE OVERSIGHT FINDINGS

    Pursuant to clause 3(c) of rule XIII of the Rules of the 
House of Representatives, the findings and recommendations of 
the Committee, based on oversight activities under clause 
2(b)(1) of rule X of the Rules of the House of Representatives 
are incorporated in the descriptive portions of this report.

                    PERFORMANCE GOALS AND OBJECTIVES

    Pursuant to clause 3(c)(4) of rule XIII of the Rules of the 
House of Representatives, the goal of H.R. 1181 is to establish 
guardrails to ensure Federal banking agencies do not coerce 
financial institutions or payment processors into surveilling, 
flagging, or debanking law-abiding citizens.

                        COMMITTEE COST ESTIMATE

    Clause 3(d)(1) of rule XIII of the Rules of the House of 
Representatives requires an estimate and a comparison of the 
costs that would be incurred in carrying out H.R. 1181. The 
Committee has requested but not received a cost estimate from 
the Director of the Congressional Budget Office. However, 
pursuant to clause 3(d)(1) of rule XIII of the Rules of the 
House of Representatives, the Committee will adopt as its own 
the cost estimate by the Director of the Congressional Budget 
Office once it has been prepared.

               NEW BUDGET AUTHORITY AND CBO COST ESTIMATE

    With respect to the requirements of clause 3(c)(2) of rule 
XIII of the Rules of the House of Representatives and section 
308(a) of the Congressional Budget Act of 1974 and with respect 
to requirements of clause 3(c)(3) of rule XIII of the Rules of 
the House of Representatives and section 402 of the 
Congressional Budget Act of 1974, the Committee will adopt as 
its own the cost estimate for the bill prepared by the Director 
of the Congressional Budget Office. However, a cost estimate 
was not made available to the Committee in time for the filing 
of this report. The Chairman of the Committee shall cause such 
estimate to be printed in the Congressional Record upon its 
receipt by the Committee.

                      UNFUNDED MANDATES STATEMENT

    The Committee has requested but not received from the 
Director of the Congressional Budget Office an estimate of the 
Federal mandates pursuant to section 423 of the Unfunded 
Mandates Reform Act. The Chairman of the Committee shall cause 
such estimate to be printed in the Congressional Record upon 
its receipt by the Committee.

                           EARMARK STATEMENT

    In compliance with clause 9 of rule XXI of the Rules of the 
House of Representatives, this bill, as reported, contains no 
congressional earmarks, limited tax benefits, or limited tariff 
benefits as defined in clause 9(e), 9(f), or 9(g) of rule XXI.

                FEDERAL ADVISORY COMMITTEE ACT STATEMENT

    No advisory committees within the meaning of section 5(b) 
of the Federal Advisory Committee Act were created by this 
legislation.

                APPLICABILITY TO THE LEGISLATIVE BRANCH

    The Committee finds that the legislation does not relate to 
the terms and conditions of employment or access to public 
services or accommodations within the meaning of section 
102(b)(3) of the Congressional Accountability Act.

                    DUPLICATION OF FEDERAL PROGRAMS

    Pursuant to clause 3(c)(5) of rule XIII of the Rules of the 
House of Representatives, the Committee states that no 
provision of the bill establishes or reauthorizes a program of 
the Federal Government known to be duplicative of another 
Federal program, including any program that was included in a 
report to Congress pursuant to section 21 of the Public Law 
111-139 or the most recent Catalog of Federal Domestic 
Assistance.

             SECTION-BY-SECTION ANALYSIS OF THE LEGISLATION

Section 1. Short title

    Section 1 provides the short title is the ``Protecting 
Privacy in Purchases Act''.

Section 2. Distinguishing firearm retailers prohibited

    Section 2 prohibits a payment card network from requiring a 
firearms retailer to use a merchant category code that is used 
only or primarily for firearms retailers, or identifies such 
retailer as engaged in the business of selling firearms, 
ammunition, accessories of firearms, or components of firearms. 
This section also prohibits a covered entity from assigning a 
merchant category code that is used only or primarily for 
firearms retailers or that identifies a firearms retailer as 
engaged in the business of selling firearms. A covered entity 
is defined as any entity that has on the date of the enactment 
of this Act, or establishes after the date of enactment, a 
relationship with a merchant for the purposes of processing 
credit, debit, or prepaid transactions.
    Section 2 grants authority to the Attorney General to 
enforce this section and shall, no later than 90 days after 
enactment, establish a process for individuals, including 
firearms retailers, to submit complaints relating to alleged 
violations. If a violation takes place, the Attorney General 
shall investigate any such complaints and provide a written 
notice to a payment card network or covered entity that 
requires the alleged violator to remedy the violation no later 
than 30 days after the recipient receives such notice. If the 
recipient of a written notice does not remedy a violation 
within 30 days, the Attorney General may bring an action in 
Federal court to enjoin the violating behavior. This act does 
not create a private right of action.
    Section 2 establishes that any State or local government 
law regulating the assignment, use, or disclosure of merchant 
category codes that are used only or primarily for firearms 
retailers is preempted. This section clarifies that nothing in 
this Act may be construed to prevent a payment card network or 
covered entity from complying with laws related to dispute 
processing, fraud, compliance management, or protecting 
transaction integrity from concerns related to illegal or 
suspicious activities, data breaches, or cyber risks.

         CHANGES IN EXISTING LAW MADE BY THE BILL, AS REPORTED

    H.R. 1181 does not repeal or amend any section of a 
statute. Therefore, the Office of Legislative Counsel did not 
prepare the report required under clause 3(e) of rule XIII of 
the House of Representatives.

    [GRAPHIC(S) NOT AVAILABLE IN TIFF FORMAT]


                             MINORITY VIEWS

    H.R. 1181 would prohibit payment card networks from using a 
Merchant Category Code (``MCC'') that distinguishes firearms 
retailers from general-merchandise retailers or sporting-goods 
retailers, and would be enforced by the Department of Justice 
(``DOJ''). The bill would also preempt state laws in this 
regard.
    Merchant Category Code is a four-digit number that credit 
card networks use to classify businesses by their primary goods 
or services to determine transaction fees and risk.\1\ The use 
of MCC in purchases notes the type of store where a purchase is 
made, but not the type of products that are bought within such 
a store.\2\ Additionally, if a financial institution offers 
cashback on purchases, the financial institution will use the 
MCC to tell which purchases were made so the cashback reward 
can be properly applied.\3\
---------------------------------------------------------------------------
    \1\ Merchant category codes (MCCs): What they are and MCC code 
lookup, Stripe (last accessed: Dec. 13, 2025).
    \2\ America's Credit Unions, In the Crosshairs: Firearms Merchant 
Category Code (Feb. 1, 2024).
    \3\ Id.
---------------------------------------------------------------------------
    In a letter opposing the bill, gun safety groups noted 
that, ``Hundreds of these MCCs exist for nearly every type of 
retailer, describing both entire industries and individual 
companies. Florists, grocery stores, fast-food restaurants, art 
dealers, automotive tire shops, and even candy stores have a 
distinct code based on retailer categories, not on the items an 
individual purchases. Algorithms have been designed to use 
these codes to filter through millions of daily transactions 
and identify key financial behaviors. This automated process 
allows creditors to detect and, when appropriate, report 
unprecedented purchasing activity at retailers that may 
indicate criminal intent or activity--from suspected fraud to 
violent crime. Originally developed for tax purposes, creditors 
now use MCC data for a range of purposes, including activity 
tracking, reporting, and risk management, while protecting the 
privacy of consumers.'' \4\
---------------------------------------------------------------------------
    \4\ See Letter from Brady, Community Justice, Everytown for Gun 
Safety, GIFFORDS, Guns Down America, and Newtown Action Alliance to FSC 
opposing H.R. 1181 (Dec. 15, 2025).
---------------------------------------------------------------------------
    These codes are standardized by the International 
Organization for Standardization (``ISO''), a non-governmental 
organization based in Geneva, Switzerland.\5\ These standards 
are typically adopted by the major credit card networks like 
Visa, MasterCard, and American Express, as well as other P2P 
platforms.\6\ In September 2022, the ISO issued standards that 
created a MCC for firearm retailers.\7\ In response to that 
designation, Republican members on FSC sent a letter to 
Amalgamated Bank voicing their concerns that the MCC code puts 
a burden on small retailers and would amount to flagging every 
firearm specific transaction as suspicious.\8\
---------------------------------------------------------------------------
    \5\ Id.
    \6\ Id.
    \7\ Ross Kerber, Global standards body approves new merchant code 
for gun sellers, Reuters (Sept. 9, 2022).
    \8\ Letter from Ranking Member Patrick McHenry to Amalgamated Bank 
(Sept. 20, 2022).
---------------------------------------------------------------------------
    In September 2023, California passed a law that would 
require use of the firearms MCC by May 2025.\9\ Groups like the 
Brady Campaign, Everytown for Gun Safety, and Women for 
American Values and Ethics were listed as supporting the 
California legislation.\10\ Additionally, Guns Down America 
applauded the implementation of the legislation in 
California.\11\ A senior official from the Brady Campaign 
stated, ``By categorizing firearm and ammunition retailers 
distinctly, financial institutions have a critical tool to 
identify and flag dangerous activity, potentially preventing 
gun trafficking and mass shooting tragedies before they 
occur.''\12\ Colardo and New York have also enacted similar 
laws.\13\ On the other hand, Florida, Texas, and other states 
have passed legislation that would prohibit the use of the MCC 
to track firearm purchases.\14\ Then in March 2024, a group of 
more than 30 Democratic Members sent a letter to the Treasury 
Department and Federal banking agencies, urging Treasury to 
issue guidance directing payment card networks and financial 
institutions to implement the new MCC for firearm and 
ammunition retailers,\15\ though such a step was not taken.
---------------------------------------------------------------------------
    \9\ Assembly Bill No. 1587 (Sept. 26, 2023).
    \10\ Senate Judiciary Committee, AB 1587 (Jul. 6, 2023).
    \11\ Guns Down America, California Implements First Merchant 
Category Code for Firearm Dealers (Jul. 4, 2024). Also see SB 24-066 
(2024).
    \12\ Id.
    \13\ See SB 24-066 (2024); Governor Kathy Hochul, Safer Street: 
Governor Hochul Signs Legislation Strengthening New York's Gun Safety 
Laws and Announces 53% Decline in Shootings (Apr. 3, 2025).
    \14\ CS/SB 214-Sales of Firearms and Ammunition (last accessed, 
Dec. 13, 2025). Also see Banking Dive, States split over gun merchant 
category code (Oct. 2, 2023).
    \15\ Letter from Senator Elizabeth Warren and Representative 
Madeleine Dean to Treasury (Mar. 27, 2024).
---------------------------------------------------------------------------
    H.R. 1181 would prohibit payment card networks from using a 
MCC to distinguish firearm retailers from other retailers and 
would be enforced by the DOJ. This Federal prohibition would 
preempt state laws, including California, Colorado, and New 
York, that require such MCC reporting, which proponents argue 
could help track suspicious purchases to prevent gun violence.
    H.R. 1181 is strongly opposed by Americans for Financial 
Reform, Brady, Community Justice, Everytown for Gun Safety, 
GIFFORDS, Guns Down America, and Newtown Action Alliance. They 
wrote, ``It is incomprehensible that Congress would choose to 
deny law enforcement a critical tool to prevent crime and mass 
violence before it happens, and to undermine state-led efforts 
to protect their constituents. Prohibiting the use of MCCs 
would prevent law enforcement and financial regulators from 
obtaining critical information that could help prevent gun 
violence and other crimes. For these reasons, we urge Members 
to oppose H.R. 1181.''
    For these reasons, we oppose H.R. 1181.
            Sincerely,
                                   Maxine Waters,
                                           Ranking Member.
                                   Al Green,
                                   Bill Foster,
                                   Joyce Beatty,
                                   Ayanna Pressley,
                                   Rashida Tlaib,
                                   Sylvia R. Garcia,
                                   Nikema Williams,
                                           Members of Congress.

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