WASHINGTON–A group of financial services organizations that includes America’s Credit Unions is reiterating longstanding concerns with the Fed’s Debit Card Issuer Survey.
With the Fed proposing to extend the survey for the next three years without revision, the groups stated 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.
According to the organizations, 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.”
Key Areas to Amend
“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 states. “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.”
Recommendations Made
The organizations are encouraging the Fed 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
- Publish additional information about the number and completeness of issuer survey responses.
The Signatories
In addition to America’s Credit Unions, other groups signing the letter included the American Bankers Association, The Clearing House Association L.L.C., The Consumer Bankers Association, the Independent Community Bankers of America and The National Bankers Association.
The letter can be read here.
