NCUA Chairman Debbie Matz has told the Federal Reserve that fordebit cards issued by federally insured credit unions with assetsof $100 million or less, the interchange costs exceed the maximumallowed under the Fed’s proposed rule.

She said in a letter to Fed Chairman Ben Bernanke that because of this, theFed should modify its proposed rule to “take into consideration theunique circumstances of smaller credit unions.’’

She told Bernanke that that the median cost per transaction was31 cents per transaction for credit unions with assets of $10million or less and is 19 cents per transaction for credit unionswith assets between $50 million and $100 million.

And direct costs don’t fall below the proposed cap until creditunions reach the $100 million to $500 million asset range.According to NCUA data, the median cost for those credit unions is8 cents per transaction.

According to the proposed rule, the allowable costs forinterchange would be limited to no more than the issuer's allowablecosts divided by the number of electronic debit transactions onwhich the issuer received or charged an interchange transaction feein the calendar year. Or the issuer could receive debit interchangecapped at 12 cents per transaction.

Matz also submitted a chart which showed that as of the callreport data through the end of March, 181 federally insured creditunions had a net positive interchange income and 111 had a netnegative interchange income.

The Fed has issued a draft rule but has been delayed in issuinga final rule because it is still reviewing the large number ofcomment letters it received on it. The new rule is supposed to takeeffect in July but there is legislation in the House and Senate that would delay theimplementation date.