On October 3, 2022, the Federal Reserve finalized a rule expanding Regulation II (Debit Card Interchange Fees and Routing), the implementing regulation for the Durbin Amendment. The final RULE is substantially similar to the proposed rule issued in 2021 and requires online (card not present) debit card transactions to be enabled for processing on at least two unaffiliated payment card networks.… Continue Reading

The Fed’s final rule implementing the Durbin Amendment (Regulation II) went into effect in October 2011.  Nearly ten years later, the final rule is still provoking controversy in the form of a new lawsuit and proposed amendments to the rule and its official commentary.

The Durbin Amendment (Section 1075 of Dodd-Frank) authorized the Fed to issue regulations to ensure that the amount of any interchange fee received by a large debit card issuer (one with at least $10 billion of assets, together with its affiliates) is reasonable and proportional to the cost incurred by the issuer. Continue Reading

In its fifth annual report on college credit card agreements, the CFPB takes financial institutions as well as colleges and universities to task for failing to adequately disclose their marketing agreements for campus financial products.  The annual report is required by the CARD Act.

The CARD Act requires institutions of higher education to disclose publicly their credit card marketing agreements. … Continue Reading

The U.S. Government Accountability Office (GAO) has joined the CFPB’s call for more transparency in the area of campus financial products.  Last week, the GAO issued a report on college debit cards in which the GAO recommended that Congress consider requiring financial institutions that provide debit and prepaid card services to colleges to publicly disclose their agreements. … Continue Reading