WASHINGTON, DC (December 9, 2025) |
Today, the Defense Credit Union Council, DCUC, joined a broad coalition of leading financial services associations and organizations in submitting a joint letter to Ann E. Misback, Secretary of the Board of Governors of the Federal Reserve System. The coalition urged the Federal Reserve to withdraw its 2023 proposed amendments to Regulation II, citing ongoing legal uncertainty and outdated data used to support the proposal.
The letter, signed by American Bankers Association; America’s Credit Unions; Association of Military Banks of America; Bank Policy Institute; The Clearing House; Defense Credit Union Council; Electronic Payments Coalition; Independent Community Bankers of America; and National Bankers Association, stressed that recent, conflicting federal court decisions have created significant uncertainty around the current and future status of Regulation II. The associations highlighted that the 2023 proposal relies on 2021 data that no longer reflects the realities of today’s debit market, especially given recent changes in payment network rules, increased fraud trends, and rapid shifts in consumer payment behavior.
The coalition further warns that lowering the regulated debit interchange cap would harm consumers, particularly low-income and underserved households, by increasing the cost of basic banking services and undermining financial institutions’ ability to serve their communities. The letter also notes that federal research suggests merchants are unlikely to pass any savings on to consumers.
While the Federal Reserve has indicated it will not finalize the proposal until active litigation concludes, the letter urges the Board to formally withdraw the rule to provide clarity to consumers, financial institutions, and the broader payments ecosystem. The coalition also called on the Federal Reserve to publish its 2023 debit card survey data, which has yet to be released, to better inform any future regulatory efforts.
DCUC remains committed to advocating for policies that protect credit union members and communities served from regulatory changes that may increase costs or limit access to affordable financial services.