January 14, 2014

OMB gives go-ahead to Fed interchange surveys

The Office of Management and Budget gave its final approval of the 2013 interchange surveys proposed by the Federal Reserve Board of Governors, biennual surveys of debit card issuers and payment card networks.

The new surveys would attempt to obtain accurate data on actual costs associated with interchange transactions. NAFCU and other amici supporting the Fed's appeal in the current interchange suit wrote the Fed jointly making suggestions for the surveys. Some suggestions were accepted, including:

  • that the Fed Board not equate PIN authentication with single-message networks and signature authentication with dual-message networks;
  • that the board will modify instructions to allow affiliated processor costs to be reported at the cost to the issuer, in certain circumstances; and,
  • that future surveys, although not the 2013 surveys, will allow 90 days for completion.

In December, NAFCU wrote the Fed on the importance of gathering such information; NAFCU Senior Vice President of Government Affairs and General Counsel Carrie Hunt wrote that it "is important for the Board to obtain an accurate idea of costs, especially giving the ongoing litigation."