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CUNA has posted its Final Rule Analysis on the interchange fee limits for large issuers and the requirements for issuers to participate on two unaffiliated networks by April 1, 2012 as well as a Regulatory Comment Call on the interim final rule on the standards large issuers must meet to receive an additional penny of interchange fee income per transaction. The Final Rule Analysis can be accessed here and the link to the Comment Call is here.  CUNA is expected to provide additional analyses of the rules in the coming days.

Some payment processors and networks have already provided guidance to financial institutions regarding the impact of the Fed's interchange rule.  Credit union debit card issuers that belong to only one network are advised to consider their options, as all issuers must participate in two independent networks under the new rule, effective April 1, 2012. CO-OP Financial Services is advising, “if your credit union is currently VISA-exclusive (VISA for signature and Interlink for PIN) or MasterCard-exclusive (MasterCard for signature and Maestro for PIN), you will need to add an unaffiliated PIN network (such as STAR, Pulse or NYCE)” but would not need to add a second signature network.

Following issuance of the final rule, TCF National Bank dropped the case it had brought against the Fed.

Acknowledging concerns expressed by Senators, credit unions, and community banks, the Fed has agreed to monitor the impact of the final rule on small issuers and has directed staff to come back to the board with two reports, one in six months and the other in 18 months, that will allow the agency to assess how the rule is affecting small issuers, including credit unions.

CUNA has told credit unions that it will be working closely with the Fed on these studies and will be reporting on their efforts along with the Fed’s reports in the coming weeks and months. CUNA said that it will continue working with the networks to urge them to adopt and maintain a two-tiered system that will allow small issuers such as credit unions, to receive as much of their current debit fee interchange income as possible. In addition, CUNA has committed to continuing communications with Senators that have promised to work to ensure the viability of the small issuer exemption and hold them to their word.