Comments essential to highlighting negative impact of Fed interchange proposal

The comment deadline is approaching for the Federal Reserve’s debit interchange proposal that America’s Credit Unions believes would dramatically harm credit unions and consumers. Comments are due May 12, and all Leagues, credit unions, and other stakeholders are encouraged to submit comments.

America’s Credit Unions maintains that the current interchange system works, that reduction in interchange income may lead to higher consumer costs, and that the Fed should withdraw its proposal.

“This issue is as important as it gets when it comes to making sure the unified credit union voice is heard. It’s crucial we provide the Fed detailed, data-backed feedback on how this proposal would impact service to consumers, especially underserved consumers,” said America’s Credit Unions President/CEO Jim Nussle. “Placing barriers in front of affordable financial products and services is never good policy, and we need to make that clear.”

Specifically, the proposal:

  • Includes a reduction in base fees from 21 cents to 14.4 cents, a decrease in the ad valorem component from 5 basis points to 4 basis points, and a fraud adjustment increase from 1 cent to 1.3 cents; and
  • Would automatically, without notice and comment, update each component of the cap every two years moving forward based on reported issuer costs.

Comments can be submitted to the Fed via the Fed’s Electronic Comment form or by email at If submitting by email, include the docket number [Docket No. R-1818] in the subject line of the message.

America’s Credit Unions has conducted research, collected data, and met with Fed governors (including Chairman Jerome Powell and Vice Chair Philip Jefferson) to share the many concerns over the proposal, and will continue engaging after the comment deadline has passed.

Credit unions are supportive of the Secure Payments Act (H.R. 7531), which would halt implementation of the rule until its impact can be studied and the industry helped coordinate a bipartisan letter from legislators expressing concerns over its impact on low-income consumers.

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