In December, the Board of Governors of the Federal Reserve System published a notice of proposed rulemaking regarding debit interchange fees and routing requirements, as a first step in fulfilling its obligations to prescribe regulations related to Section 1075 of the Dodd-Frank Wall Street Reform and Consumer Protection Act. Public commentary regarding this proposal may be submitted to the board on or before Feb. 22, 2011.
As of this writing, over 175 public comments are posted to the board’s website set aside for this purpose, and many more are likely to be submitted prior to the deadline. The comments are typically from individuals, credit unions, community banks and trade groups, and they raise a myriad of concerns with the board’s initial effort, not just in general terms but also with respect to its specific proposals and alternatives, and the likely effects of the proposed regulation (if finalized) on consumers, merchants and on small issuers of debit cards alike. Perhaps not surprisingly, relatively few comments indicate broad support of the proposal as written.
