According to a consortium of industry organizations representing the majority of debit card issuers, the Federal Reserve's proposed interchange fee cap reduction would significantly impact smaller financial institutions’ ability to maintain robust fraud prevention.

Current Challenges

In a letter to the Board of Governors of the Federal Reserve System, the industry group pointed out that the proposed cap reduction comes as the growing threat landscape demands sustained investment in fraud prevention technologies and processes.

Resource Constraints

Community financial institutions are already operating in a challenging environment. Since 2011, exempt institutions have experienced a 13% decrease in debit card interchange revenue for single-message network transactions. As the Community Depository Institutions Advisory Council recently noted, financial institutions rely on this revenue stream to cover increases in operating expenses to implement fraud prevention and mitigation measures.

Concurrent Industry Changes

According to the consortium, the proposal will add to a growing list of significant operational changes affecting fraud prevention, including:
  • · Implementation of new card-not-present routing requirements
  • · Network rule updates shifting additional fraud liability to issuers
  • · Increased adoption of contactless and mobile wallet payments
  • · Growth in PIN-less card-not-present transactions

Infrastructure Concerns

Of particular interest to fraud specialists is the industry group’s observation that some single-message networks may not have sufficiently robust security systems to combat card-not-present fraud, in contrast to dual-message networks – a technical disparity that becomes more significant as routing requirements evolve.

Outdated Data

The letter also points out that the proposal is based on data from 2021, which predates significant market changes like routing requirement implementations, network rule modifications affecting fraud liability, and shifts in payment technology adoption patterns.

Professional Implications

According to the letter, the fee cap changes would pose significant challenges to fraud prevention at community banks and credit unions, including:
  • Maintaining effective fraud monitoring systems with potentially reduced resources
  • Adapting to increased card-not-present fraud exposure
  • Balancing customer experience with enhanced security measures
  • Planning for future fraud prevention investments

Looking Forward

In their letter, the consortium stressed the importance of sustainable funding for security measures, pointing out that the ability to invest in fraud prevention technology and maintain skilled personnel directly affects institutions' risk management capabilities.

What Do You Think?

Do you agree with the industry group’s assessment? How would you approach maintaining robust security programs while adapting to the potential changes?