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: