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These fees were deemed not "materially" different The cap, which has remained
from 2011 when the cap took effect. unchanged for the past 12 years,
• The "average fee" for exempt transactions processed amounted to a compromise that
over dual-message networks "gradually increased"
from 51 cents to 64 cents during that same time did little to quell the imbroglio
frame, while the fee for those processed over single- over interchange.
message networks fell from 31 cents to 27 cents.

• Fraud losses on debit card payments have been Gov. Bowman raised another issue which could well hold
rising, from 7.8 basis points in 2011 to 17.5 basis up the cap revision. Last year the Fed adopted a rule change
points in 2021. that required debit card issuers to program their cards so
that merchants could choose from at least two networks
Rainey said in her statement that the Fed's 2021 data bears to process debit card payments, only one of which can be
out the concerns of community bankers in that is shows owned by Visa or Mastercard. That rule change took effect
"low-volume issuers operate their debit card programs at this past July.
a loss due to their disproportionately high authorization,
clearing and settlement costs, demonstrating the Fed's debit "We do not yet know the effects of those revisions, and
interchange caps are not 'reasonable and proportional' as I would have preferred that the [Fed] Board pause to
required by the Dodd-Frank Act." collect data on evolving conditions before proposing this
rule change, and follow a more deliberative approach for
"The Federal Reserve claims to be a data-driven regulator, future updates to the interchange fee cap," Gov. Bowman
and as such, has the responsibility to ensure its data inputs wrote.
actually tell the full story," Rob Nichols, president and
CEO of the American Bankers Association, said. "With
this proposal, the Federal Reserve is calling into question Patti Murphy, self-described payments maven of the fourth estate, is
not just the end result, but the process itself, which has senior editor at the Green Sheet. She also co-hosts the Merchant Sales
lacked transparency and public engagement." Podcast, and is president of ProScribes Ink (www.proscribes.net)

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