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Tuesday, July 27, 2010 - Last week, President
Obama signed into law the Dodd-Frank Wall Street
Reform bill. Among the provisions important to PMAA
marketer members, two took effect immediately upon
enactment. Retailers may now offer customers’
discounts based on the form of payment (cash, check,
credit card and debit card); however, retailers are
not permitted to offer discounts between brands of
credit card and brands of debit card. Therefore, a
retailer can offer discounts of cash versus debit,
cash versus credit, cash versus check, check versus
debit, check versus credit and credit versus debit.
Several other important provisions will take effect
over the next year. These provisions require reports
from federal agencies and require these agencies to
write new regulations including the Federal Reserve.
The Federal Reserve will have until April 2011 to
do the following:
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Issue regulations to establish standards for
assessing whether interchange transaction fees
on debit cards are reasonable and proportional
to the cost incurred by the issuer with respect
to the transaction.
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Issue regulations to establish standards for
making adjustments for fraud.
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Issue regulations regarding network fees. Such
authority is limited to ensuring that a network
fee is not used to compensate an issuer with
respect to an electronic debit transaction.
In July 2011:
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Regulations issued in April 2011 are effective.
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Regulations shall be issued regarding the number
of networks on which an electronic debit
transaction may be processed and limit
restrictions on network routing.
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The Federal Reserve Board shall issue a report
on government prepaid cards and the fees charged
with respect to such cards.
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