The Federal Reserve did not survey small debit card issuers about their costs of issuing before it issued rules that will directly impact their income from debit card interchange.

According to the Federal Reserve's proposed debit interchange rule, the agency surveyed 131 debit card issuers with assets of over $10 billion in assets about their costs of issuing debit cards and received responses from 89. It did not mention surveying any smaller issuers about what they pay to issue debit cards.

CUNA and NAFCU reported working with the Fed on the survey, but it is unclear whether they reported the debit issuing costs of any specific credit unions.