ICBA urged the Federal Reserve to provide regulatory relief on the Debit Card Issuer Interchange survey, which is used to implement Regulation II debit card interchange standards.
Details: In a comment letter to the agency, ICBA said the survey is flawed, thus the data that the Fed relies on for debit card reports and its Reg II rulemaking is incomplete and flawed. ICBA added:
The Issuer Debit Card Survey requests more than 260 data points and is estimated to require 160 hours to complete.
The survey has not been changed in 15 years, and many requested data elements lack relevance.
The data requests are frequently impossible for community banks to report due to the misalignment between survey instructions and operational realities.
Recommendations:
ICBA recommended streamlining the 250 data points to fewer than 100, significantly reducing the regulatory burden on community banks.
ICBA recommended updates to measure debit card fraud.
ICBA asked that payment facilitators (such as Clover, Stripe, and Toast) provide data to show they are passing on Durbin Amendment debit card savings to small businesses.
ICBA joined a joint trades letter that requested more accurate collection of authorization, clearing, and settlement costs.