|Hill Payments Charter Letter||116th Congress||10/15/20|
|Hill Payments Charter Letter 9.29||U.S. House Task Force on Financial Technology||09/29/20|
|Joint Letter on Direct Deposit||Senate Banking and House Financial Services Committees||08/28/19|
|House Letter on Facebook's Libra Proposal||House Financial Services Committee||07/16/19|
|Senate Letter on Facebook's Libra Proposal||Senate Banking Committee||07/15/19|
|Joint Letter on H.R. 85||U.S. House of Representatives||02/28/19|
|Comment Letter on Reg J and FedNow||Federal Reserve Board||09/08/21|
|ICBA Reg II FRB NPR Comment Letter||Fed||08/11/21|
|Federal Reserve PSR Policy Comment Letter||Fed||08/02/21|
|Joint Comments on Fed Accounts Proposal||Fed||07/12/21|
|Comments on Third-Party Sender Roles and Responsibilities||Nacha||07/01/21|
|Comment Letter on Amendments to Rules Concerning Prepaid Accounts Under the Electronic Fund Transfer Act (Regulation E) and the Truth in Lending Act (Regulation Z)||CFPB||04/13/21|
|ICBA Response to Nacha Same Day ACH Dollar Limit Increase RFC||01/22/21|
|Comment Letter Regarding Application of Kraken Financial for Access to Federal Reserve System Services||Fed||10/05/20|
|ICBA FedNow Comment Letter||Fed||09/10/20|
|Joint Trades Letter on Proposed Payments Charter||OCC||07/29/20|
|ICBA Statement for HFSC Fintech Hearing 9-29-2020||HSFC||09/29/20|
|The Future of Real-Time Payments||House Financial Services Committee's Task Force on Financial Technology||Robert A. Steen||09/26/19|
|Facilitating Faster Payments in the U.S.||Senate Banking Committee||Robert A. Steen||09/25/19|
Washington, D.C. (Aug. 11, 2021) — The Independent Community Bankers of America (ICBA) today said the Federal Reserve Board should not update debit card interchange regulations without first fully analyzing the effects of the proposed changes on consumers and financial institutions.
In a comment letter, ICBA said that while most community banks already comply with the proposed clarifications, the agency should not alter the regulatory environment for banks amid the ongoing COVID-19 pandemic.
“While the Durbin Amendment is poor public policy that has been empirically proven to harm consumers and the viability of local financial institutions in favor of ‘big box’ and large e-commerce retailers, community banks continue to comply with its provisions,” ICBA President and CEO Rebeca Romero Rainey said today. “ICBA calls on the Fed to study the potential impact of updating its interchange regulations before proceeding with a new rule to ensure it is in the best interest of consumers.”
The Fed board’s proposal clarifies existing rules requiring debit card issuers to ensure that at least two unaffiliated payment card networks have been enabled for debit card transactions, including for card-not-present transactions.
The existing rules implement the Dodd-Frank Act’s Durbin Amendment, which was designed to reduce interchange fees but has instead transferred billions of dollars from small financial institutions to large merchants, which have not passed their savings on to consumers and small businesses.
In today’s comment letter, ICBA said:
The Independent Community Bankers of America creates and promotes an environment where community banks flourish. ICBA is dedicated exclusively to representing the interests of the community banking industry and its membership through effective advocacy, best-in-class education, and high-quality products and services.
With nearly 50,000 locations nationwide, community banks constitute 99 percent of all banks, employ more than 700,000 Americans and are the only physical banking presence in one in three U.S. counties. Holding more than $5 trillion in assets, over $4.4 trillion in deposits, and more than $3.4 trillion in loans to consumers, small businesses and the agricultural community, community banks channel local deposits into the Main Streets and neighborhoods they serve, spurring job creation, fostering innovation and fueling their customers’ dreams in communities throughout America. For more information, visit ICBA’s website at www.icba.org.