ICBA and other groups sent a letter to the Federal Reserve urging it to withdraw its 2023 debit interchange proposal until there is legal certainty in several court cases. ICBA and the other groups noted that:

• The cases have conflicting rulings on the original Regulation II, making any final rulemaking on the 2023 proposal highly questionable.
• Leaving the debit card market in limbo creates uncertainty for issuers, networks, and merchants.
• Debit fraud remains the top fraud issue, according to the Federal Reserve’s 2024 Financial Institution Risk Officer Survey.