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CUNA Suggests Improvements to Fed Card Issuer Survey
Friday, October 14, 2016 6:45 AM

The Federal Reserve Board should develop a card issuer survey that completely and accurately captures issuer cost data related to electronic debit transactions, CUNA wrote to the board this week. Along with several other trade organizations, CUNA's letter requests such a survey, one that does not place a unique burden on those required to complete it.

The Federal Reserve Board issued a series of questions and proposed revisions for public comment regarding the biannual debit card issuer survey the board uses to facilitate its administration of the Electronic Fund Transfer Act and the related Board regulation.

“The issuer survey is an important tool for the Board in fulfilling its ongoing obligations,” the letter reads. “We believe that there would be substantial benefit to the board, debit card issuers, and the debit card marketplace if the issuer survey was revised as recommended in this letter.”

To achieve this objective, CUNA strongly encourages the board to:

  • Commence the survey not earlier than Feb. 15 of 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 that 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 that may hinder the board’s ability to conduct a comprehensive analysis.