comment letter
CBA-BPI Reg II Overview
Regulation II A proposal that would make checking accounts more expensive by cutting debit revenue by a third
On October 25, the Federal Reserve Board (the “Fed”) issued a rulemaking that would lower the maximum amount of interchange revenue that most debit card issuers can earn (the “Fee Cap”). This would be the first adjustment of the Fee Cap since it was introduced by a 2011 Fed rulemaking.
The “Durbin Amendment” to the Dodd Frank Act requires the Fed to ensure that debit interchange fees are “reasonable and proportional” to debit issuer costs relating to debit transactions.
