The Clearing House Association along with the American Bankers Associations and several other trade associations (the “Associations”) submitted a joint letter to the Federal Reserve Board of Governors reiterating longstanding concerns over its Interchange Transaction Fees Survey. The letter explains that the current survey fails to fully capture the range of costs incurred by debit card issuers, a problem that could be exacerbated if the Board adopts automatic updates to the interchange fee rule as it has previously proposed. 

The Associations argue that the current survey paints an incomplete picture of issuer costs, which could misguide policy decisions affecting the entire debit card ecosystem. Among other things, the Associations urge the Board to:

• Publish overdue 2023 survey data;
• Revise the survey to reflect modern issuer costs such as cardholder inquiry costs, non-sufficient funds costs, and tokenization costs; and
• Increase transparency about the number and completeness of survey responses.

To read the full letter, click here.