The Clearing House Association led a broad trade association coalition in submitting comments on the Federal Reserve’s proposal to gather data and associated information regarding interchange fees from payment card networks and debit card issuers. To facilitate information collection the Board has issued drafts of four surveys. Two surveys, one for debit card issuers and one for payment card networks, will collect information on costs, debit card usage, and interchange fees. The Clearing House’s letter strongly encourages the Board to revise each of the surveys to: (i) ensure that the Surveys elicit complete and accurate information reporting, (ii) establish a formal approach to answering respondent questions, (iii) ensure that the Surveys collect sufficient data to reflect all costs associated with debit card programs, (iv) ensure that the Surveys do not collect data that is of dubious value and likely to be misleading, particularly regarding incentive payments, and (v) ensure that the reporting burden falls on the proper party.