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Hopefully, none of you own Visa or MasterCard stock which took a hit last week after the Fed announcement.

Under article 10 of the Dodd-Frank Act (Durbin Amendment), The Federal Reserve met last week to discuss the proposed new debit card interchange requirements among other items on the agenda.

Many expected the Feds to propose sizable cuts in debit card interchange. However, I believe most were blindsided with the proposal by the Federal Reserve staff.

It was recommended that debit interchange be capped at 12 cents. This represents a substantial reduction in debit interchange. It appears the proposed interchange cap will be for both signature based and PIN based debit transactions, although proposal was a little ambiguous.

The feds may listen to more arguments especially on fraud cost from the banks. However, some sort of new interchange rates will go into effect in July. We’ll see if they remain at the 12 cent cap. However, even if there is a slight adjustment, they will be substantially lower than the current interchange.

This is a great opportunity
If your merchants are priced on a “cost plus” pricing schedule, this is a great opportunity for you to talk to your existing merchants and let them know that because you care about them, you put them on a pricing plan that would provide them reduced debit costs as soon as the regulations go into effect (July 2011).

Be aware there will be ISO’s/rep who will try to take advantage of your merchants by confusing them with 12 cent + cost rates for credit cards even though the rates apply to debit only. Therefore, you need to start communications with your merchants immediately.

This is also a great time to review your files for merchants currently on tiered pricing plans who you did not sign recently. If you have been in the business as long as I have you remember the Wal-Mart suit of 2003. Many acquirers and ISO’s never gave the merchant the reduced debit card rates from that suit. The same thing will happen with this rate reduction. Let perspective merchants know that your cost plus plan will entitle them any fed mandated cost reductions as soon as they become available.

If needed, I’ll be glad to run cost analyses for perspective tiered-priced merchants at a 12 cent + cost rate so they can see the substantial cost savings should the 12 cent cap be mandated. Hopefully, this will open their eyes and earn you the account.

I also want you to be aware, that should this mandate be implemented, the banks won’t just sit back and take a multi-billion dollar yearly loss from debit card revenue. Article 10 of the Dodd-Frank Act mandates that banks cannot add extra fees to offset the debit card interchange reduction. However, you and I both know that banks won’t just sit back and take a multi-billion dollar loss. Banks will add fees or reduce cost elsewhere. They may add monthly fees to customer accounts, reduce reward points on cards, or they may change the whole debit card program to a prepaid debit card program since prepaid cards are not part of the Dodd-Frank Act. We’ll see want happens.

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