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CUNA & Financial Trade Groups Meet with FRB on Debit Interchange

On October 24, 2012, representatives from the Credit Union National Association (CUNA) and other financial trade associations met with Louise Roseman, Director of the Reserve Bank Operations and Payments Systems Division at the Federal Reserve Board (Board), to advocate that the debit interchange fee caps should include certain additional costs incurred by issuers, as detailed in a joint letter submitted to the Board this August.  In the joint letter, CUNA asked the Board to consider including, under the debit interchange fee caps, international fraud losses in the calculation of the fraud loss ad valorem, as well as previously-excluded costs related to cardholder inquiries.  CUNA continues to have significant concerns that, under the Board’s debit interchange rules, market forces will ultimately drive down the debit interchange fees that the exemption for smaller institutions is intended to protect.  CUNA supports the inclusion of additional costs that debit card issuers currently incur to provide debit card programs, under the debit interchange fee caps.