Debit-Card Routing Requirements

Leaving its interchange-fee restrictions intact – at least for now – the Federal Reserve has finalized its proposal expanding on its existing requirement that all debit- card transactions must be enabled for processing on at least two unaffiliated payment-card networks for card-not-present transactions.  Although the rule does not address the still more contentious question of the ceilings on debit-card interchange fees, it does indicate that the FRB may turn to these.  Any change in permissible fees would have still more dramatic impact on bank and network- provider income, benefiting merchants, tech-platform companies, small networks, and perhaps also consumers if merchants pass along any savings and new networks prove robust.

INTERCHANGE11.pdf