Joint Trades Letter to Fed regarding Issuer Survey & Reg. II

October 11, 2016


Robert deV. Frierson
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, D.C. 20551


Re: Proposed Agency Information Collection Activities; Comment Request:
Proposed Revision to Regulation II Debit Card Issuer Survey (FR 3064a)
and Request for Comment on Information Collection Proposal


Dear Mr. Frierson:


The Board of Governors of the Federal Reserve System (the “Board”) recently issued for public

comment a series of questions and proposed revisions regarding the biannual debit card issuer

survey (the “Issuer Survey”), pursuant to which the Board collects certain information to

facilitate the Board’s ongoing administration of Section 920(a) of the Electronic Fund Transfer

Act (“Section 920(a)”)1 and related Federal Reserve Board Regulation II (“Regulation II”).2 The

American Bankers Association, The Clearing House Association L.L.C., the Consumer Bankers

Association, the Credit Union National Association, The Financial Services Roundtable, the

Independent Community Bankers of America, the Mid-Size Bank Coalition of America, and the

National Association of Federal Credit Unions (collectively, the “Associations”) respectfully

submit this letter in response to the Board’s request for comment, published in the Federal

Register on August 9, 2016.3 The Associations appreciate the opportunity to provide comments

on the proposed revisions to the Issuer Survey.



The Associations acknowledge the significance of the Issuer Survey as a tool in the Board’s

ongoing implementation of Section 920(a). The information gathered from the Issuer Survey

and the Board’s use of that information may impact significantly the debit card marketplace.

Consequently, the Associations and the debit card issuers they represent have an interest in 

ensuring that the Board collects comprehensive, accurate debit card cost information, and that

any Board action influenced by the Issuer Survey is grounded in an understanding of the existing

debit card marketplace and the true costs associated with operating a debit card issuing

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