The Clearing House Association, joined by eight other trade associations, filed a letter with the FRB emphasizing the extraordinary breadth and depth of organizations and Government officials that have expressed concerns similar to those expressed in the associations’ February 22 comment letter to the Board on its proposed rule to implement the debit card interchange provisions of Dodd-Frank. The letter also addresses suggestions that governments in other countries have capped or eliminated debit card interchange fees without any negative consequences to consumers or debit card issuers in those countries, focusing particularly on the experience in Canada where consumers have ended up paying slightly more than the current debit interchange fee of 44 cents received by U.S. issuers. On July 20, 2011 the FRB published in the Federal Register its final Regulation II, implementing the Durbin Amendment. The rule, which differs from the Board’s December 16 proposed rule, caps interchange fees for debit card transactions at 21 cents plus an ad valorem component of five basis points as an adjustment for fraud losses. A debit card transaction interchange fee that does not exceed this threshold is conclusively deemed reasonable and proportional. The FRB also approved an interim final rule that allows an issuer to receive an adjustment of 1 cent to its interchange transaction fee if the issuer complies with certain fraud prevention standards outlined by the FRB. The interchange fee limitations and the interim final rule are effective October 1, 2011.