CUNA has written a letter to the Federal Trade Commission objecting to the way the commissioncharacterized the impact of the Durbin amendment's interchange cap on credit unions.

The characterization came in a report the FTC published as partof an appropriations measure.

The Durbin amendment capped the amount of interchange that debitcard issuers of over $10 billion can receive for transactionscardholders validate with a personal identificationnumber.

The measure exempted smaller financial institutions, includingmost credit unions, from the cap but also mandated changes to thenumber of debit transaction processing networks which all financialinstitutions must use.

CUNA took issue with commission's report, arguing that it onlybriefly touched on the impact the cap was having on credit unionsand asserting the FTC drew only on “selective information” fromreports generated by the Federal Reserve and the GovernmentAccountability Office.

“The FTC's study does not include significant information fromthe GAO report that helps to present a more complete assessment ofthe impact of Section 1075 on credit unions and small banks,” CUNAwrote, pointing out that the GAO had documented a decline in creditunion debit card interchange of about 5% and that it had explicitlyleft open the possibility of further declines in the future.

“The agency's report should have noted that additional datareflects recent declines in interchange fee income, particularlyfor PIN transactions,” CUNA contended. “Also, it should haveacknowledged that it is very early in the implementation of Section1075 and that further data, as the Federal Reserve Board intends toprovide on an annual basis, is needed to present a balancedassessment of the impact of Section 1075 on credit unions and smallbanks.”