Fed must amend Debit Card Issuer Survey to capture full range of costs
America’s Credit Unions and other financial services organizations wrote to the Federal Reserve Monday, reiterating longstanding concerns with the Fed’s Debit Card Issuer Survey. The Fed has proposed to extend the survey for the next three years without revision, and Monday’s comments note the Board of Governors’ “use of the limited information provided therein has a significant adverse impact on the debit card marketplace by painting an incomplete picture” of costs incurred by debit card issuers.
Finalizing the Fed’s 2023 proposal to update the debit interchange cap every other year by directly linking the cap to the data in the issuer survey would make an even more significant and direct negative impact, the organizations note.
“The Board should amend the Issuer Survey in several key areas to ensure that it captures the full range of costs incurred by issuers with respect to electronic debit card transactions, while balancing the burden on those required to complete the Issuer Survey,” the letter reads. “These amendments would help to ensure that the Issuer Survey more accurately reflects the current state and features of the debit card marketplace, which would enhance the value of the survey responses to the Board and to other stakeholders.”
To achieve this objective America’s Credit Unions and the organizations strongly encourage the Board to:
- Publish the 2023 issuer survey data;
- Revise the survey to capture all costs incurred by the issuer with respect to electronic debit transactions;
- Amend survey to better reflect the current state of the debit card marketplace; and
- Publish additional information about the number and completeness of issuer survey responses.
America’s Credit Unions remains staunchly opposed to any government price control efforts on debit card interchange fee caps.
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