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FRB: Electronic Fund Transfer Act, Request for Information on Debit Card Fee Study

ABA Contact: Nessa Feddis
Published: May 21, 2004 Federal Register
Comments Due: July 23, 2004
Disposition: Filed July 20, 2004

Summary:

The Federal Reserve Board is conducting a study about the disclosures of debit card fees, at the request of member of the US Senate Banking Committee. In connection with the study, the Board is soliciting comment on whether the existing disclosures required by the Electronic Fund Transfer Act adequately inform consumers of fees imposed by the account-holding institution when its customer uses a debit card at POS.

The Board also seeks comment on the need for, and the potential benefits of requiring additional disclosures on periodic statements to reflect fees imposed by account-holding institutions for debit card use. Lastly, it seeks comment on the benefits of requiring disclosure of the amount, source, and recipient of each such fee, as well as a summary of the total amount of such fees for the period, and calendar year-to-date.

ABA's Comment:

ABA commented that the existing disclosures are more than adequate to inform and alert customers of POS debit card fees imposed by the account-holding institution and that altering these disclosures or adding to them will achieve little in terms of educating customers, but will impose unnecessary costs and add to the ever-growing and frustrating regulatory burden. We specifically opposed the proposal to aggregate such fees on a monthly and calendar year-to-date basis. ABA also wrote that, as a practical matter, it is not feasible to construct a system that would allow disclosure of the account-holding institution’s POS debit card fee at the time of transaction.

2004 Regulations Chart
Federal Register
Comment Letter

Questions? Please contact Nessa Feddis for more information.