Interchange fees are a nominal charge that offsets the costs of operating a payment system that is extremely beneficial to consumers and retailers alike. When retailers accept electronic payments – credit cards, debit cards or mobile payments – they enjoy numerous advantages, including increased sales, access to a broader customer base, reduced risks associated with handling cash, fewer bounced checks and guaranteed payments.

For these benefits, retailers pay a Merchant Discount Fee, which encompasses the interchange fee. This fee covers costs associated with customer service, system operations, data protection and card production. These services make electronic payments viable, valuable, and popular among consumers and retailers.

The infrastructure supporting electronic payments is complex and expensive. It involves significant operational costs for software, hardware, labor, network processing and fraud prevention. Card issuers bear considerable risks, including fraud and insufficient funds, while continually investing in technology and cybersecurity to keep transactions safe and efficient. This secure system took decades and billions of dollars to build and maintain.

In 2010, the Durbin amendment was introduced as part of Dodd-Frank, aiming to cap interchange fees on debit card transactions. However, the rapid implementation of this amendment, with minimal review, led to significant unintended consequences. Despite promises from retailers that savings from reduced interchange fees would be passed on to consumers, these savings have not materialized. Instead, the reduction in interchange fees has strained financial institutions, particularly smaller community banks.

The impact of the Durbin amendment has been profound. Financial institutions have faced increased costs and decreased revenue, affecting their ability to offer free checking accounts and maintain robust fraud prevention measures. This situation is particularly concerning given the rise in consumer fraud, with the Federal Trade Commission reporting that consumers lost over $10 billion to fraud in 2023 alone. Reducing interchange fees could further limit funds available for securing systems and combating fraud, leaving consumers more vulnerable.

The Federal Reserve is considering a proposal to further reduce the regulated interchange cap on debit cards under Reg II. The proposed changes include:

• Lowering the base component of the interchange fee from 21 cents to 14.4 cents.
• Decreasing the ad valorem component from 5 basis points to 4 basis points of the transaction value.
• Increasing the fraud prevention component from 1 cent to 1.3 cents per transaction. 

While these changes might seem minor, their cumulative impact could be devastating for financial institutions and their customers. Enacting the proposed Credit Card Competition Act would impose unnecessary and burdensome restrictions on credit card routing and limit banks’ freedom to choose networks, potentially compromising transaction safety and security. Additionally, requiring banks to accept all merchant transaction types could lead to frequent card re-issuance, causing inconvenience for consumers and potentially prompting community banks to stop offering credit cards altogether.

This proposed legislation, effectively “Durbin 2.0,” goes beyond its initial intentions by expanding government routing mandates into the credit card market, which would stifle competition, limit consumer choice and undermine the principles upon which our economy thrives.

Given these concerns, the IBA urges the Federal Reserve to withdraw the proposed rule on interchange fees and for Congress not to move forward with the Credit Card Competition Act. The IBA calls for a comprehensive analysis of the costs and benefits of any changes to interchange fee regulations, including up-to-date data and consideration of the full range of costs incurred by financial institutions, as well as the impact on consumers, especially the unbanked and underbanked.

While the intent behind these proposals is to lower consumer costs, the reality has been far different. The IBA believes that maintaining a reasonable interchange fee structure is essential for the health of our banking system, the security of electronic payments and consumers’ financial well-being. Therefore, the IBA urges the Federal Reserve, regulators and lawmakers to carefully consider the real-world impacts of further reducing interchange fees and to take a balanced approach that supports both financial institutions and their customers.