#interchange – Federal Financial Analytics

26 01, 2023

DAILY012623

Eliza Allen2023-01-26T16:44:02-05:00January 26th, 2023|2- Daily Briefing|

Effective Date Set for LIBOR Termination

The Federal Register today includes the FRB’s final rule Implementing the Adjustable Interest Rate (LIBOR) Act, setting the rule’s effective date as February 27. As noted (see FSM Report LIBOR9), the final rule settles many LIBOR transition questions in favor of SOFR, leaving numerous complex implementation questions up in the air despite this added certainty.

Fed Study Finds Card Rewards Result in $15 Billion Wealth Transfer

A new Federal Reserve staff study finds that credit-card rewards annually redistribute approximately $15.1 billion a year to more financially-sophisticated consumers. This result is likely to weigh heavily into debate later this year if, as we expect, Sen. Durbin (D-IL) reintroduces legislation to force card-routing alternatives to Visa and Mastercard (see FSM Report INTERCHANGE10).

ISDA Lays Groundwork for Crypto Rules, Law

The self-regulatory body for global derivatives, ISDA, today released a contractual framework for digital-asset derivatives. These are now likely to be widely adopted by major financial institutions but may not resolve legal-ownership issues when cryptoasset entities use intermediaries or other avenues into global capital markets that obscure contractual rights.

Daily012623.pdf…

29 11, 2022

DAILY112922

Eliza Allen2022-11-30T11:20:13-05:00November 29th, 2022|2- Daily Briefing|

Fed Finalizes Revisions to Interchange Survey

After finalizing a controversial proposal opening up debit-card routing (see FSM Report INTERCHANGE11), the FRB has also set changes to reporting on interchange-fees proposed in July. The final requirements track the proposal, gathering data now on reporting changes when multiple networks are involved in processing transactions as well as revising the survey to prevent overcounting certain transactions.

Senate Finance Chair Challenges Crypto-Exchange Conduct

Continuing Congressional pressure on crypto following FTX’s collapse, Senate Finance Chairman Wyden (D-OR) today sent six letters to some of the largest crypto exchanges to determine if the factors leading to FTX’s collapse are widespread. It is unclear what Sen. Wyden intends to do with the information he requests given that his panel does not have jurisdiction over the conflicts of interest and related concerns he cites, but it can surely call hearings and at the least build a record for the kind of legislation Mr. Wyden may support.

Daily112922.pdf…

14 11, 2022

DAILY111422

Eliza Allen2022-11-14T17:00:05-05:00November 14th, 2022|2- Daily Briefing|

FSB Thinks 2020 Reg Relief Could Go, Stay – It All Depends

In conjunction with the G20 summit, the FSB has released a policy paper assessing the extent to which various pandemic-related regulatory forbearances should be continued.

FSB Reiterates Climate, Crypto, NBFI Plans

The FSB head’s letter to the G20 today reiterates all of the priorities expressed in its October letter to G20 finance ministers.

Regulatory Hearings to Address Last-Gasp 2022 Agenda, Position Panels for a Busy New Year

With GOP House and Democratic Senate control largely assured, this week’s hearings with Messrs. Barr, Gruenberg, Harper, and Hsu will illuminate not only current priorities – most notably what’s next for federal crypto law and rule – but also the very different priorities HFSC and Senate Banking will advance in the next Congress.

FRB-NY Staff: Big U.S. Banks Remain Extremely Resilient

In its latest assessment of the vulnerability of the fifty largest U.S. BHCs, Federal Reserve Bank of New York staff confirmed the overall rosy assessment of bank resilience in the Board’s latest financial-stability report (see Client Report SYSTEMIC94).

OCC Ramps Up Fair-Lending Enforcement

In remarks delivered for Acting Comptroller Hsu, Senior Deputy Comptroller for Bank Supervision Policy Grovetta Gardineer reiterated that ensuring fairness is a top OCC priority.

Gruenberg Finally Gets the Nod

Knowing now that he has secured Democratic Senate control into next year, President Biden today finally and formally nominated Acting FDIC Chairman Gruenberg to assume the chairmanship.

Daily111422.pdf…

11 10, 2022

INTERCHANGE11

Eliza Allen2022-10-12T10:22:34-04:00October 11th, 2022|1- Financial Services Management|

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…

7 10, 2022

AL101022

Max Camateros-Mann2022-10-12T10:23:24-04:00October 7th, 2022|3- This Week|

Why It’s Nice to be Majority Whip

Although the Senate will come back on Tuesday for what will be an almost pro-forma session, one big item is likely to come to the Senate floor: the national Defense Authorization Act (NDAA). This must-pass bill may seem far afield from financial policy, but Majority Whip Durbin (D-IL) has moved aggressively to position his bill to impose interchange-fee restriction once credit cards akin to his now famous “Durbin Amendment” for debit cards (see FSM Report INTERCHANGE10). The first restrictions on what ends up in the NDAA include what leadership wants and that the amendment has the patina of having something to do with national defense.

Al3101022.pdf…

3 10, 2022

DAILY100322

Eliza Allen2022-10-05T10:29:43-04:00October 3rd, 2022|2- Daily Briefing|

Gruenberg Commits to Climate-Risk Standards, Cautious on Premium Hike

Acting FDIC Chairman Gruenberg today strongly defended banking-agency action addressing climate risk, indicating that the FDIC will advance pending risk-management principles akin to those pending from the OCC (see FSM Report GREEN12) along with working with the Fed.

FRB-Chicago Study: Big U.S. Banks are Oligopolists

A new Federal Reserve Bank of Chicago working paper finds that U.S. banking has become increasingly concentrated judged by the top-five bank’s market share and a standard market-power index, concluding that this “oligopolistic” sector is thus able to charge undue fees to weaker corporate customers.

Warren Zelle Report Finds “Rampant” Fraud, Slams Banks

Following the hearing with large-bank CEOs (see Client Report REFORM213), Sen. Warren (D-MA) released a scathing report concluding that Zelle is plagued by “rampant and increasing fraud.”

Board Defies Critics, Demands Two Networks for Online Debit Transactions

Ahead of possible Congressional action on legislation to restrict credit-card interchange fees (see FSM Report INTERCHANGE10), the FRB today voted 6-1 to finalize its controversial proposal (see FSM Report INTERCHANGE8) requiring debit-card issuers to enable at least two unaffiliated payment-card networks, including with regard to “card not present” transactions.

FSOC Presses New Law, Rule, Supervisory Standards to Tackle Crypto Systemic Risk

As anticipated, the FSOC today approved a sweeping report on cryptoasset financial stability, finding that interconnectedness between this sector and the financial system poses significant risk that warrants structural action.

Daily100322.pdf…

30 08, 2022

DAILY083022

Eliza Allen2023-01-03T16:41:05-05:00August 30th, 2022|2- Daily Briefing|

FRB-Atlanta: Cardless Consumers Pay More Per Transaction

After the Fed announced imminent FedNow liftoff, the Federal Reserve Bank of Atlanta yesterday issued a release summarizing research that concludes that lower-income consumers pay considerably more per each payment transaction due the use of cash and debit cards that do not provide credit-card rewards and the overall price increase that merchants charge to compensate for interchange fees.

Oversight Subcomm Chair Presses Agencies on Crypto Oversight, Jurisdictional Warfare

The Chairman of the House Oversight Committee’s Subcommittee on Economic and Consumer Policy, Rep. Raja Krishnamoorthi (D-IL), today sent letters to Treasury, the SEC, the CFTC, the FTC, and several major crypto exchanges demanding information and documents showing what each is doing to combat cryptocurrency-related fraud. Calling for improved regulation and guidance, the Chairman criticizes regulators for their insufficient coordination in response to escalating risks.

Daily083022.pdf…

29 07, 2022

DAILY072922

Eliza Allen2023-01-04T13:45:23-05:00July 29th, 2022|2- Daily Briefing|

Credit-Card Routing Expansion Introduced, Faces Long Odds

As anticipated, Sens. Marshall (R-KS) and Durbin (D-IL) have introduced S. 4674, legislation to extend routing-system requirements to credit cards.

FDIC, Fed Crack Down on IDIs Working with Crypto Companies

In addition to joining the Fed in sending a stern warning to Voyager about misrepresenting FDIC insurance, the FDIC today issued an advisory instructing IDIs as to how best to partner with crypto companies to prevent future misunderstanding and ensure compliance with the agency’s new rule (see FSM Report DEPOSITINSURANCE113).

BIS Lays Out Risks to Central Bank Green Assets

The BIS Consultative Group on Risk Management today released a report detailing the data and methodological challenges faced by central banks implementing climate risk into their reserve-management frameworks.

FTC Takes on Payment Processing

The FTC today unanimously reached a settlement with the nation’s largest payment processor, First American, related to what some call “trick-and-trap” practices.

BIS Advances Cross-Border PVP Payment Options

Hoping to speed the introduction of payment versus payment (PvP) systems to reduce frictions in cross-border payments, the BIS today released a call for information that details previous PvP proposals and asks for comment on them.

HFSC Republicans Expand CFPB Attack to State-AG Partnerships

Continuing their campaign against CFPB Director Chopra, HFSC Republicans have sent him a letter accusing the Bureau of intimidating companies by pursuing duplicative enforcement actions with state regulators.

Daily072922.pdf…

13 07, 2022

DAILY071322

Eliza Allen2023-01-06T15:18:57-05:00July 13th, 2022|2- Daily Briefing|

Small Business Committee Urges Fintech Transparency, New CFPB Role in Fintech Lending

Today’s Small Business Subcommittee on Oversight, Investigations, and Regulations hearing on fintech transparency focused on financial practices that may harm small businesses’ access to credit.

HFSC Party Lines Form on CRA Rewrite

As anticipated, the Subcommittee on Consumer Protection and Financial Institutions today held a hearing examining the banking agencies’ proposed rule to modernize the CRA (see FSM Report CRA32).

Fed Proposes Debit-Card, Payment-System Data Collections

Although the Fed has yet to finalize a controversial proposal related to debit-interchange fees (see FSM Report INTERCHANGE8), it has proposed changes to how it collects debit-card information essential to implementing changes to network selection and, should it come to do so, fee calculations.

FSB Chair Reiterates Need for Crypto Regulation, Highlights Progress on Climate Roadmap

FSB Chair Klaas Knot’s letter today to the G20 ministerial reiterated all the points regarding COVID exit strategies, regulation of cryptoassets, and executing FSB’s climate roadmap outlined after June’s plenary meeting.

Senate Democrats Demand More Stringent, Binding Fed Ethics Standards

Senate Banking Committee Chairman Sherrod Brown (D-OH) joined by four other Democrats today sent a letter to Chairman Powell again calling for more stringent, enforceable Fed ethics standards, and reminded Mr. Powell in strongly-written arguments about the need to do so via binding regulation or by the kind of statutory change they have already introduced.

Global Regulators Press for Global Stablecoin Payment-Risk Standards

Doubtless spurred by FSB requests and market …

4 05, 2022

INTERCHANGE9

Max Camateros-Mann2023-03-01T14:41:27-05:00May 4th, 2022|5- Client Report|

Swipe-Fee Disclosures, Antitrust Pressure Likely Following Senate Hearing

As anticipated, bankers and card networks squared off with merchants at today’s Senate Judiciary hearing addressing credit-card interchange fees. Chairman Durbin (D-IL) strongly defended his amendment restricting debit-card fees, arguing that expanding fee constraints and network-competition provisions to credit cards would reduce inflation and increase consumer spending power. He did not, however, propose legislation to do so, instead pressing for transparency; we expect the CFPB to include a mandate for swipe-fee disclosures in the changes it plans shortly to propose to current card disclosure requirements (see Client Report CONSUMER42).

INTERCHANGE9.PDF…