WASHINGTON--America’s Credit Unions and other financial services organizations, including the American Bankers Association, wrote to the Federal Reserve Monday reiterating 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 the organizations encouraged 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
- Publish additional information about the number and completeness of issuer survey responses
The Defense Credit Union Council said it's "unacceptable" that the Fed is relying on a "flawed and antiquated" debit‑card issuer survey to justify sweeping changes to interchange rules.
"By moving forward based on outdated, narrow data—and excluding small issuers and community institutions—the Fed is undermining competition, stifling consumer choice, and threatening the viability of credit unions nationwide. We demand the central bank immediately halt any regulatory action until a comprehensive, transparent, and inclusive data collection process is in place," said DCUC Chief Advocacy Officer Jason Stverak.