DES MOINES, Iowa (April 23, 2024) – Last week, Gov. Kim Reynolds signed a bill into law that prohibits financial institutions operating in the state from requiring a credit card merchant code to track the purchases of firearms and ammunition.

The House Commerce Committee introduced House File 2464 (HF2464) on Feb. 20. The new law prohibits a financial institution operating in Iowa from requiring or assigning a firearms code that distinguishes a firearms dealer from any other retailer. “Firearms code” is defined as “a merchant category code approved by the international organization for standardization specifically for firearm dealers.” It is now also illegal to deny a transaction based solely on the acquirer’s assignment of a firearms code to the firearms retailer.

On April 11, the Senate passed HF2464 by a 45-0 vote. The House previously passed the measure 68-27. The bill was amended before passing in the Senate to remove the legal definition for “customer.” The House concurred by a vote of 73-24 on April 16. Gov. Reynolds signed it into law on April 19.

Under the law, government entities are prohibited from keeping a registry of privately owned firearms or the ownership of privately owned firearms.

The state attorney general is tasked with investigating alleged violations and given the sole authority to pursue legal action in district court if an alleged violator does not cease doing so 90 days after receiving a notice from their office. Those found guilty of violating the law are subject to a fine of no more than $1,000 per violation.

In response to legislation like HF2464, the major credit card payment networks have “paused” implementation of the firearms merchant code. In an email to Reuters, a Mastercard representative said such bills would cause “inconsistency” in how the code could be applied by merchants, banks, and payment networks. The more states that ban such codes, the more likely this program gets scrapped permanently.


In September 2022, the International Organization for Standardization (ISO), based in Switzerland, approved a new merchant category code for firearm and ammunition merchants; In a letter to payment card networks, federal lawmakers stated that the new Merchant Category Code for firearms retailers would be “. . .the first step towards facilitating the collection of valuable financial data that could help law enforcement in countering the financing of terrorism efforts”, expressing a clear government expectation that networks will utilize the new Merchant Category Code to conduct mass surveillance of constitutionally protected firearms and ammunition purchases in cooperation with law enforcement;

The new Merchant Category Code will allow the banks, payment card networks, acquirers, and other entities involved in payment card processing to identify and separately track lawful payment card purchases at firearms retailers in the State of Iowa, paving the way for both unprecedented surveillance of Second Amendment activity and unprecedented information sharing between financial institutions and the government; This potential for cooperative surveillance and tracking of lawful firearms and ammunition purchases will have a significant chilling effect on citizens wishing to exercise their federal and state constitutional rights to keep and bear arms in Iowa.


Concern about the misuse of firearms databases isn’t just paranoia. The Taliban has reportedly used a firearm ownership database created by the U.S. government to track down gun owners and confiscate firearms in Afghanistan. This goes to show that even if you trust the people creating the database, it can fall into the wrong hands. In other words, the very existence of a database is a danger.

The feds can share and tap into vast amounts of information gathered at the state and local level through fusion centers and a system known as the “information sharing environment” or ISE.

Fusion centers were sold as a tool to combat terrorism, but that is not how they are being used. The ACLU pointed to a bipartisan congressional report to demonstrate the true nature of government fusion centers: “They haven’t contributed anything meaningful to counterterrorism efforts. Instead, they have largely served as police surveillance and information sharing nodes for law enforcement efforts targeting the frequent subjects of police attention: Black and brown people, immigrants, dissidents, and the poor.”

Fusion centers operate within the broader ISE. According to its website, the ISE “provides analysts, operators, and investigators with information needed to enhance national security. These analysts, operators, and investigators…have mission needs to collaborate and share information with each other and with private sector partners and our foreign allies.” In other words, ISE serves as a conduit for the sharing of information gathered without a warrant. Known ISE partners include the Office of Director of National Intelligence which oversees 17 federal agencies and organizations, including the NSA. ISE utilizes these partnerships to collect and share data on the millions of unwitting people they track.

In practice, local data collection using ALPRs, stingrays, drones and other spy technologies creates the potential for the federal government to obtain and store information on millions of Americans including phone calls, emails, web browsing history, location history, and text messages, all with no warrant, no probable cause, and without the people even knowing it.

In a nutshell, without state and local assistance, the feds have a much more difficult time gathering information. When the state limits surveillance and data collection, it means less information the feds can tap into. This represents a major blow to the surveillance state and a win for privacy.


HF2464 takes effect July 1, 2024.

TJ Martinell

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