Regulation II Proposed Changes Could Lead to Decreased Debit Interchange

CCUA Urges CUs to Act Now

In the Association’s continuing effort to represent the interests of member credit unions before the Federal Reserve Board (“Fed”), a survey to develop a comment letter on a pending proposal is open. The Fed is proposing to revise Regulation II to expand the requirement for debit cards to be able to be processed by at least two unaffiliated networks to apply to card-not-present debit card transactions, such as online purchases and mobile payments. The Fed believes that it is now feasible to expand the prohibition on network exclusivity arrangements to card-not-present transactions, such as online purchases, because of technological advancements and the development of new payment market infrastructure since 2011.

It remains the goal of the Association to submit a robust comment letter to the Fed on behalf of members. Accordingly, to provide accurate details and local credit union impact, the input of member credit unions is needed. The Association remains concerned that the proposed changes to Regulation II could lead to decreased debit interchange and increased compliance costs. Detailing member regulatory concerns to the Association will ensure an impactful comment letter.

The deadline to respond to the Association’s survey has been extended and the new deadline is August 6. The survey may be found at:

In the interim, a template comment letter is available at Grassroots Action Center | CUNA Please note that the subject line should not be changed to ensure that individual comments are properly filed with the Fed.