NAFCU presses Fed to ensure accurate data in interchange surveys
Dec. 18, 2013 – NAFCU is encouraging the Federal Reserve to invite debit-card issuers with less than $10 billion in assets to voluntarily participate in its 2013 interchange surveys in an effort to obtain accurate data on actual costs associated with interchange transactions.
Hunt, NAFCU’s senior vice president of government affairs and general counsel, said in a letter Tuesday that adding the small issuers to the survey is unlikely to burden the Fed. However, these issuers stand to be disproportionately affected if, as NAFCU expects, the Fed’s current debit interchange fee cap becomes the default rate for all issuers.
Gathering information from the small issuers “is important for the Board to obtain an accurate idea of costs, especially given the ongoing … litigation” targeting the Fed’s debit interchange rule, she wrote.
The 2013 surveys will be the first since the Fed’s 2011 surveys of debit-card issuers and payment-card networks.
NAFCU and other amici supporting the Fed’s appeal in the current suit also wrote the Fed jointly on the proposed surveys. Briefly, the associations urged that the board, in conducting the surveys:
- allow at least 90 days for respondents to complete them;
- remove misleading differentiations of payment card networks;
- promote complete and consistent responses;
- repeat the individualized issuer follow-up protocols from 2011; and
- ensure that full debit-card cost data are captured accurately and completely.
The groups want the Fed to ensure it captures accurate information on the costs of authorization, clearing, and settlement and to “avoid insufficiencies and imprecision that may hinder the Board’s ability to conduct a comprehensive analysis.”
NAFCU comment letter