ARLINGTON, Va. — NAFCU has told the Federal Reserve that the group likes its idea of creating an exception for receipts on purchases under $15, but said the regulator could do more.

"NAFCU generally supports the creation of a small-dollar exception; however, we would recommend that the threshold for the receipt requirement be raised from $15 to $25," NAFCU President/CEO Fred Becker wrote in a comment letter to the Fed. Currently, receipts are required for all electronic funds transfer transactions at electronic terminals, regardless of the amount.

Becker asserted that $25 would be consistent with current payment card association rules, including minimum chargeback limits, and that anecdotal evidence suggests that consumers tend not to retain receipts for transactions under $25 anyway.

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NAFCU said that, "terminal receipts are often cost-prohibitive or impractical for certain low-dollar transactions. As such, the receipt requirement has impeded efforts of merchants, particularly small businesses, to offer cashless payment options for small-dollar transactions of generally minimal significance…NAFCU believes that the creation of a small- dollar exception will promote consumer choice by facilitating the ability of consumers to use faster and more convenient electronic payment methods for low-dollar purchases."

At the same time, Becker acknowledged the importance of these receipts in helping consumers better manage their accounts, but the proposal "strikes a suitable balance." However, some NAFCU members have expressed concerns about consumer awareness that they will not receive a receipt for smaller transactions and asked the Fed to closely monitor the issue. "If the Board learns that consumers are confused about the lack of an available receipt, NAFCU suggests that it may be appropriate to require a posted notice on electronic terminals that will not generate a receipt for small dollar transactions, to ensure that consumers are sufficiently informed of that fact. A brief and concise disclosure would serve to reduce the costs associated with fielding consumer questions while imposing minimal burdens on merchants," he said.

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