The American Bankers Association and five financial sector associations this week reiterated their longstanding concerns about the Federal Reserve’s Debit Card Issuer Survey, saying that policy based on the limited information gathered from the survey has had adverse effects on the debit card marketplace.
The Electronic Fund Transfer Act requires the Fed to publish data every two years on interchange fees and other costs incurred by debit card issuers and payment card networks. The Debit Card Issuer Survey has been conducted for more than two decades as part of that mandate. The information gathered from the survey was used to shape a proposed rule in 2023 to amend Regulation II to lower debit interchange fees by almost 30% and institute a biennial review of the cap without accompanying public comment each time. The rule has not been finalized.
In response to a recent Fed request for comment, the associations urged the agency to revise the survey to more accurately capture the current, comprehensive costs incurred by debit card issuers to better inform policymaking. Specifically, they said the Fed should publish the 2023 survey data; revise the survey to capture all costs incurred by the issuer with respect to electronic debit transactions; amend it to better reflect the current state of the debit card marketplace; and publish additional information about the number and completeness of survey responses.
“It is critical that board policy be informed by robust, accurate and complete data,” they said.
