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In both Lansing and Washington, D.C., MCUL is working alongside our partners at America's Credit Unions to make sure the voice of the credit union industry is heard. Through weekly updates, a year-long events schedule and countless grassroots events held throughout the state, MCUL is dedicated to continually educating legislators and regulators about the difference credit unions make, both here in Michigan and at the national level.

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MCUL Submits Comments to Federal Reserve Board on Proposed Debit Interchange Fee Rule

On Friday, MCUL submitted comments to the Board of Governors of the Federal Reserve System opposing their proposed rule on Debit Card Interchange Fees and Routing. This proposed rule would make significant revisions to Regulation II’s interchange fee cap. Specifically, the proposed revisions would update all three components of the interchange fee cap based on the latest data reported to the Board by covered issuers regarding debit card transactions performed in 2021. Under the proposal:

Additionally, the proposal would codify in Reg II an approach for updating the three components of the interchange fee cap every other year going forward based on the latest data reported to the Board by covered issuers, without opportunity for public comment.

In our opposition, we strongly urged for the withdrawal of the proposed rule, citing decades of research showing the adverse effects of the Durbin Amendment and the current regulation and detailing how additional price controls would impact credit unions who are technically exempt from the proposed rule. Although the proposal maintains the established threshold of $10B in assets for an institution to be covered, we discuss how smaller institutions have faired under the current regulation and how a further reduction in interchange fees will effect the operations that are funded by these revenue streams. In particular, we detail how:

Given these, we joined the industry-wide call to immediately withdraw the proposed rule.

Read the full comments here.

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