CBA Files Comment on Reg II.

On Tuesday, October 11, 2016, CBA and other trades submitted a comment letter to the Federal Reserve Board in response to recently issued questions and proposed revisions to the biannual debit card issuer survey.  The Board collects certain information to facilitate the its ongoing administration of Section 920(a) of the Electronic Fund Transfer Act and related Federal Reserve Board Regulation II.


CBA advised the Board should develop an Issuer Survey completely and accurately capturing issuer cost data related to electronic debit transactions without placing undue burden on those required to complete the survey.  CBA strongly encouraged the Board to:


  • Commence the Issuer Survey no earlier than February 15 in the applicable years, and allow at least 90 days for respondents to complete it;
  • Eliminate the breakdown of fixed and variable costs as the Board has proposed; and
  • Revise the survey to ensure full debit card program data are captured accurately and completely, particularly with respect to costs of authorization, clearing, and settlement, and to avoid insufficiencies and imprecision which may hinder the Board’s ability to conduct a comprehensive analysis.


CBA also urged the Board to revise the Issuer Survey to address these concerns.