The deadline for credit unions to complete America’s Credit Unions’ (ACU) debit card interchange program survey and help shape ACU’s comment letter to the Federal Reserve Board is Friday, January 12. You can complete the survey here.
To deliver a data-informed comment letter to the Federal Reserve Board, ACU (formerly the Credit Union National Association and National Association of Federal Credit Unions) is asking all credit unions to complete this important survey. An email was sent in late December from ACU (formerly CUNA) with a request to complete this survey (from cunaresources@cuna.coop).
The Federal Reserve Board is considering a proposed rule that would significantly reduce the debit interchange fee cap, which would further impact non-interest income at credit unions after the Durbin Interchange Amendment was implemented through regulatory action in 2011.
While the proposal exempts financial institutions with less than $10 billion in assets, the Durbin Amendment’s “exemption” of smaller financial institutions has proven to be largely illusory, as the regulatory thresholds in the interchange market do not insulate smaller issuers from harm. ACU and the American Association of Credit Union Leagues (AACUL) released a study that shows mandated interchange caps negatively impact local and community financial institutions such as credit unions. Additionally, the California and Nevada Credit Union Leagues published its own executive summary and analysis.
The Leagues and ACU know the proposed rule is seriously flawed and will cause significant harm to credit unions and their members, which is why solid data is important to create a full picture of credit unions’ experience. Since the proposal was developed based on data collected from financial institutions with $10 billion or more in assets, ACU will need to illustrate why the proposed rule would have major ramifications on the industry and hurt credit union members.
If you have questions related to this initiative, please email Leagues Vice President of Regulatory Advocacy and Compliance Lisa Quaranta or Senior Vice President of Federal Government Affairs Stephanie Cuevas.
Thank you in advance for your participation!
