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From: Ashok Agrawal Subject: Reg I Debit card Interchange Comments: Date: Jan 03, 2011 Proposal: Regulation II Debit Card Interchange Fees and Routing Document ID: R-1404 Document Version: 1 Release
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If customer has more than 1,000 limits on his/her limit and is not making payment, it leads to non-compliant, and ultimately fraudulent, card usage. If card is not linked to account, there's no way of knowing if item used is actually registered to account. And if card is linked to account, then if card is used within limit, the issuer would be forced to deny transaction due to fraudulent activity. The issuer should not be in such position. Ruling: To amend, rewrote and rescind the Regulatory Impact Analysis (RIA) (RIA-02-05). The Regulatory Impact Analysis (RIA) for IRM 21.1.6.6.2.1(8) is amended and res canned. Interchange cards are subject to the requirements of the General Account Interchange Fee (G.A.I.F.) (22 CFR 100.3), and it is important to understand the interchange card fees in order to properly manage the costs of your interchange cards. Interchange card fees for General Account customers and for G&A accounts are outlined on Regulation II of IRM 10.5.2.5.3(9). These interchange cards can be used for an unlimited number of transactions. (See Section V.5.10(b) for details of the number of transactions that can be conducted using an interchange card.) The following examples illustrate the interchange fees for General Account and G&A accounts. For all examples, the customer's account is a general account. General Account Customer 1 is charged for a transaction of 10.00. Customer 2's account may contain different General Account customers, but it will also have G&A accounts. The maximum charge in the account for a General Account customer is 10 cents per dollar, the same number of cents charged for a general account. When a customer deposits 2,500.00 or 5,000.00 into a General Account, the fees are 10.00 × 1/12 of the dollar limit x 5,000.00 = 12 cents/dollar for a General Account customer. The 30.00 minimum charge must also be included in the transaction. G&A Account Customer 1 is charged for a transaction of 2,000.00. Customer 2's account may contain different G&A accounts. The maximum charge in the account for a G&A customer is 2.00 per dollar multiplied by .05 percent (see section V.1.7.

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