NAFCU has written a letter to the Federal Reserve expressing concerns that the debit interchange cap that the Fed is currently writing may wind up impacting credit unions as well as large banks.

The financial reform law that put the cap into place mandated it only for institutions of more than $10 billion in assets, but NAFCU and other cap opponents have long maintained that it would effectively cap all debit interchange.

"I understand that the statute directs the Board to set an interchange fee for institutions with more than $10 billion in assets," wrote NAFCU CEO Fred Becker in a Nov. 19 letter to Louise Roseman, director of the Division of Reserve Bank Operations and Payment Systems at the Fed.

"I also understand that the Board has little control over the market's reaction after the rule is published. However, the Board can and should consider the likely consequences of the rule during this stage in the process," Becker said.

"Indeed, given that the Federal Reserve Board is, essentially, the chief regulator of the U.S. economy, it is sound policy to consider the likely consequences of the regulations it promulgates."