Page 10: "Under Amex’s NDPs, the merchant...may not impose a 'parity surcharge' on credit card transactions, meaning a surcharge in which the merchant assesses the same surcharge amount on all credit card brands and does not surcharge debit cards at all."

That page is getting into the weeds, but none of that says a merchant cannot state that cash and debit cards receive an x% or $x discount.

The federal regulations specifically allow discounts, and presumably some lawyers will argue that a surcharge is different from a discount.

Amex is trying to do all it can, but still can’t tell a merchant they cannot advertise a discount for cash/debit.