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Oh great. Drawing conclusions on a 10 year old study, of a product that has existed for less than 20 years. Surely NCUA cannot glean this kind of data from call reports.
This is ridiculous, at this point even a really cheap transaction cost for just a pre-auth costs at the least 3.5 cents which is above the 2 cents they have listed this does not take into consideration telcom, and as the Debit Expert said fraud and associated programs that have just come into play in the last 3 years.
If what is stated is true, that NCUA used data from 2001, that was the early days of the debit world. Fraud and other costs were much lower at that time. Debra Matz has now lost her credibility.
Great. Just great. Is NCUA trying to push the self-destruct button? Is there no filter on the information they decide to share?
Thanks for pointing out another area NCUA is simply clueless about.
This is extremely incorrect and damaging information that NCUA has presented. They have not taken into account nor considered that most CU's also allow free ATM access for our member accounts, Home Banking, Bill Pay, etc... which is taken into account along with debit interchange to support the basic checking program for our members. As of yesterday, it was announced that Chase, Citi & B of A are seriously looking at charging $3 - $5.00 on ATM withdrawals to make up for this potential debit interchange loss of income to support again...all the expenses to support checking accounts for the consumer without imposing really large monthly fees (which they've all already implemented). Question...where did NCUA obtain these numbers and was it even truly and properly validated?
I don't know where the NCUA got their "direct costs" from but those aren't the costs in our credit union.
Plus, it's not the direct costs -- but the "Indirect Costs" that are the most damaging --Fraud prevention; fraud losses; and card re-issues due to card compromises. Most of which are the result of the Retailer's continued failure to abide by data security requirements and willingness to accept knowingly fraudulent cards since they have no liability).
I am afraid the NCUA's comments will have devasting effects on small credit unions and sincerely question NCUA's motives. Are they here to please Washington or represent all the credit unions?
I'm so appalled and upset. This is unreal and almost unbelievable. I've done studies on our debit card program and we are close to a billion and they must not have including any costs except for direct processing and no actual or preventitive fraud costs ro re-issue costs. This is the most flawed study and could cause irreprehensible harm. How do we contact the NCUA!
How are they calculating the assessments!!!
Our "Indirect Costs" are the ones that cause us the most harm in our debit program, fraud prevention, insurance and actual loss. Card re-issues due to the failure of Washington to reign in retailer's lack of data security. We basically offer debit at barely break even. I agree with many of the other comments that the NCUA's flawed analysis will cause more harm than good.
Why should anyone be surprised! As Chip speculates NCUA does not know the issues and/or impact of the Debit Card Interchange proposal on credit unions yet they way in with a study that is worthless.
I'm with you Jason. In one fail swoop NCUA has taken away all our work we put into fighting the cap on interchange. The data is terribly flawed and it shows how out of touch NCUA is with the credit unions they serve.
I think I am on my forth reissue of cards in past year due to the lack of security on the part of merchants. They have to take these type of "indirect costs" into account.
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