Federal Reserve building
A coalition of six financial trade associations submitted a joint letter to the Federal Reserve Board on July 28 urging the agency to revise and delay its proposed changes to the Interchange Transaction Fees Survey (FR 3064). The groups raised concerns over increased reporting burdens and the reliability of the data being collected.
The letter, signed by organizations including America’s Credit Unions, the American Bankers Association, the Independent Community Bankers of America, the Clearing House Association, the Consumer Bankers Association and the National Bankers Association, stated: “We urge the Board to consider these comments and not to move forward with a final notice or begin data collection until the industry has had an opportunity to review the changes, provide input and reasonably prepare.”
The groups emphasized that the Federal Reserve should avoid finalizing changes without further dialogue. “We believe that a better outcome could be achieved by the Board first publishing a revised proposal for further comment after it has had time to consider the suggestions made in this letter,” the trades wrote.
They also criticized the survey for underrepresenting issuer costs, arguing it “has a significant adverse impact because of its use in setting a cap on debit interchange fees.”
The letter urged the Fed to ensure any future data collection process “captures the full range of costs incurred by covered issuers while limiting reporting burden.”
The groups said they remain committed to working with the Board to improve the survey design and data quality without imposing excessive burdens on issuers.
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