The Clearing House Association, along with eight other trade associations, submitted a comment letter strongly urging the Federal Reserve Board to fundamentally revise its proposed rule on debit card interchange fees. The proposed rule imposes a fixed cap on interchange fees that the FRB admits will prevent banks and credit unions from recovering even the basic costs of providing debit card services. Hence, the letter urges the FRB to revise its rules and allow issuers to receive fees that, as specified by the Durbin Amendment, are reasonable and proportional to the issuers’ actual costs with respect to debit card transactions. The letter also asks the FRB to follow its mandate from Congress to carefully consider the impact of any price regulation on consumers, financial institutions and the U.S. payments system as a whole.