The Federal Reserve's proposed rule limiting debit interchange fees would have a "significant adverse effect on and in some cases dire consequences" for the 70% of credit unions that offer debit cards and the Fed should work with Congress to delay implementation by two years to further study the issue.
Those are among the key arguments made by CUNA in the comment letter it filed with the Fed late yesterday.
CUNA Senior Vice President and Deputy General Counsel Mary Mitchell Dunn wrote that the Fed's proposal doesn't protect small issuers and many of those financial institutions fear that payment networks may not provide a two-tiered structure that differentiates between issuers with assets of over and under $10 billion.
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