Extension would help ‘accuracy, specificity’ of debit proposal feedback

June 3, 2021

CUNA and other organizations requested the Federal Reserve extend the comment deadline on a proposal that could increase costs and complexity for debit card routing requirements. Comments are currently due July 12, CUNA requested a 30-day extension.

The proposed rule would require debit card issuers to offer two unaffiliated networks which must also be capable of processing transactions under a new framework of expectations surrounding merchant type, transaction and location. Currently credit unions can comply with regulations by issuing debit cards carrying a signature network and an unaffiliated network.

“The proposal is highly complex and it will take time for the Associations to gather needed information from our member institutions… The NPRM’s thin regulatory analysis makes it more difficult for financial institutions and consumers alike to analyze the effects of the proposal or to comment without conducting significant independent data analysis,” the letter reads. “The accuracy, specificity, and overall quality of the Association’s comments will be enhanced by the additional time.”

The organizations also note the pandemic continues to present operational difficulties, and “additional time would permit a more thorough review of the NPRM and the various implementation-related and other challenges it presents and would allow a more robust opportunity for engagement.”

CUNA previously shared concerns about this proposal in a letter to the Senate Banking, Housing, and Urban Affairs Committee.