Debit Interchange and Fraud

The Federal Reserve Board has proposed reducing debit interchange fees. Although the reduction would only technically apply to institutions over $10 billion in assets, the MBA believes all banks will be significantly impacted by this proposal (similar to the events following the original debit interchange limitations in Regulation II which was required by the Dodd-Frank Act). The base debit fee rate would be reduced by roughly 30% to 14.4 cents from 21 cents. Additionally, the ad valorem component would decrease from 5.0 basis points to 4.0 basis points and the fraud-prevention adjustment would increase from 1.0 cents to 1.3 cents.

Your responses to this survey will help us better articulate why this proposal is dangerous for the banking industry, our customers and our communities.
1.What is your bank asset size?
2.How much has your debit interchange income reduced since the implementation of Regulation II?
3.Did your bank implement new fees after the introduction of Regulation II interchange limits to offset debit interchange fee reduction?
4.Are you likely to implement new account/debit program fees if additional limits are placed on debit interchange income?
5.Would you consider ending your debit card program if additional debit interchange limitations were implemented?
6.In percentage total, how much has debit card fraud increased for your bank in the last 3 years?
7.Are there any other thoughts or comments you would like to share about how your bank would respond to additional Federal Reserve limitations on debit interchange fees?