In Bank of America, the Federal Circuit continued a recent trend toward rejecting the Sixth Circuit's Scripps decision and concluding that district courts do not have jurisdiction over stand-alone overpayment interest suits over $10,000. This may herald a decisive change, with a decision on the issue by the Eleventh Circuit in Paresky likely next year. The decision has a significant impact on Bank of America, under the Federal Circuit's interest netting decision in Wells Fargo, and also has possible implications in other areas.