Does pin debit still matter in a post-Durbin Amendment credit card processing world? Yes, and technology can make a huge difference. This example shares how much money auto dealers will save based on two different sales amounts. In addition to pin-debit as a transaction type, routing to the lower cost pin debit network can also reap substantial savings.

Cost Comparison Analysis for Signature versus Pin Debit effective 9/2012 with an average $200 ticket

Cost Comparison Analysis for Signature versus Pin Debit effective 9/2012 with an average $25 ticket, common for oil changes. 

Merchant Discount is the basis points you pay your merchant processor. Your discount may vary.

Notes:

• .9% pin debit network rate used in this example. Debit network rates vary and under new regulations, all debit cards must offer two networks for processing.
• Visa/Mastercard dues and assessments apply to signature debit, but not pin debit.
• Regulated cards average 65-70% of all debit card transactions
• With your current credit card terminals, who decides whether to prompt customers for pin debit or signature debit?  Is that the best option for you to control costs?

Why do dealers need debit routing technology?  It’s evident from the above examples that merchant costs vary depending on multiple factors. The fact is that leaving it up to employees to make decisions about pin debit is not going to result in the greatest savings to the dealership. With our SaaS technology, the intelligent payment engine will dynamically route transactions based on internal intelligence, plus rules you create.  Do you always want the lowest cost? Or do you want to reduce risk even if it costs more? (Consumer dispute period is 14 days on pin debit vs 120 days for signature debit.)

DEALER COMMENT: I already use a virtual terminal in our dealership.

CHRISTINE:   What is your average pin debit penetration? Do you know? How easy is it to find out? Does your virtual automatically route to the lower cost debit network? What percentage of your transactions qualified for the best qualified rate possible? A virtual terminal often works just like your old dial up terminal- it has no intelligence and does very little to help merchants reduce costs or mitigate risks.

DEALER COMMENT:  How will I know if your routing technology works?

CHRISTINE: Our merchant portfolio averages 76% of all eligible debit transactions converted to pin debit. Merchants have this information in real-time by user, by store/department, by enterprise. Additionally, some dealers choose to have a report emailed automatically if the percent falls below a certain rate. This alerts them of a potential hardware or other problem. The executive dashboard has many easy to read graphical and downloadable key metrics that auto dealer groups have asked for. Additionally, you can create and distribute custom reports on any metric to a distribution list on any schedule. You can also dig into your merchant statement.

DEALER COMMENT: We don’t want to change processors.

CHRISTINE: You don’t need to. We’re processor agnostic and connect to all the major processors.

DEALER COMMENT:  What’s involved to get set up? How much does it cost?

CHRISTINE:  Most dealers choose to use a signature capture terminal. You can buy from any source, or we’ll help you get them wholesale. Cost varies by dealer, with pricing on a transaction basis. Dealers rarely choose our  CenPOS payment technology for cost savings. It’s just one more benefit- efficiencies and reporting are the two key reasons auto dealer groups use our technology.

Contact Christine for more information on pin-debit routing solutions.

Credit card processing is evolving from dial up terminals to web based virtual terminals, even for the retail environment. These hosted solutions are not all alike. Addressing just the pin debit function for payment processing, CenPOS and SkipJack perform differently. The hardware set up for each in this scenario is a virtual terminal, magnetic stripe card reader and pin pad.

• The Skipjack user must look at the consumer card and ask if it will be ‘debit or credit’.
• The CenPOS user will automatically prompt the customer for their pin number IF it fits the merchant settings.

What’s the difference?

With Skipjack, employee decisions at the point of sale impact merchant risk and cost of accepting credit cards. With CenPOS, the customers and employees are prompted automatically to achieve the desired result at the point of sale. CenPOS is an intelligent payment platform that routes transactions based on merchant settings for risk tolerance and payment costs.

Statistically, CenPOS merchants achieve a national average of over 75% pin debit conversion. Merchants can verify this information for their account in the executive dashboard, and also create alerts for their conversion rate, such as if it falls below a certain percent.  While I don’t know other product statistics, published reports of aggregate retail merchants are substantially lower- less than 30%; most businesses I encounter  have under 10%.

What’s the merchant benefit to increase pin debit conversion?

• 14 days for a dispute period vs 120 day for signature debit.
• Tougher to lose disputes.
• Dues and assessments do not apply.
• Additionally, the Durbin Amendment requires 2 debit networks on every card. With CenPOS least  cost routing, the debit transaction will be routed to the lower cost network, according to all applicable rules.

DISCLAIMER: This review uses publicly available information posted on the competitive product web site as of 7/01/2012. The article does not address all features, just the pin debit conversion. Skipjack is a registered trademark of Skipjack Financial Services, Inc.

EDITOR CHRISTINE SPEEDY COMMENTS:

• According to their web site http://www.skipjack.com/solutions.aspx?cmsphid=85781357|4347063|2831168, “PIN-based debit is currently available only for Canadian merchants.” However, I don’t think that is accurate.
  
• Regardless of the features you need, CenPOS generally outperforms Skipjack when all the facts are compared, especially for automotive and business to business applications.
• API is available to integrate into ERP and other software packages.

WHERE TO BUY

CenPOS is sold through direct agents and resellers. There is also a referral program. Click here to become a CenPOS agent, reseller, or referral partner.  Click here to become a customer or call the hotline at the top of this web page.

Which merchants will receive the new low debit fee rates? This video provides a detailed look at rate differences and how to examine your merchant agreement schedule A and statement. While all merchants qualify for them, only a fraction will actually have debit discounts passed down from their processor. Will you be one of them? Pull out your merchant statement, then watch the video so you can compare data.

On October 1, 2011, new debit interchange rates go into effect as a result of the Durbin Amendment, part of the Dodd-Frank Wall Street Reform Act.

The semi-annual Visa and MasterCard interchange update for October 2011 is coming soon. Merchants can expect debit interchange modifications in support of the Dodd-Frank Wall Street Reform and Consumer Protection Act in addition to other interchange changes.

As a review, there will be two types of debit interchange- regulated and non- regulated depending on whether the card issuing bank is exempt or not. A Card Issuing Bank is considered nonexempt from the regulated debit interchange rates when the banks assets, together with its affiliates, exceed $10 billion.  Under the law, the maximum interchange fee that a non exempt card issuer may receive for an electronic debit transaction (signature and pin debit) will be $0.21 per transaction, plus 5 basis points. This provision is effective on October 1, 2011. That is not the maximum merchants will pay to processors, just the maximum the card issuing bank can receive.

The Board also approved an additional $0.01 adjustment towards the issuer’s debit card interchange fee if the issuer develops and implements policies and procedures designed to achieve the fraud-prevention standards outlined in the interim final rule, which is still open for public comment until September 30. Banks will likely quickly qualify for the extra $.01 as they try to eek out as much as they can under the new regulation.

For merchants to receive the new non-exempt debit rate:

1. The merchant must have a price plan ( schedule A) with pass through interchange indicated.

OR

2. The merchant processor must pass on the savings.

If you’re not sure whether you can qualify for new interchange rates, contact us for a free consultation. We’ll need to see a merchant statement and a copy of your contract pricing, usually with “Schedule A”  at the top. A proposal you received is not adequate for review.

I just received a robo call pitching how due to changes under the Durbin Amendment I could now save money and process direct from Visa & MasterCard, not from a broker. Most deposits are the next day.

I couldn’t resist. I pressed 1 to speak to an operator.  A nice man came on the line, whom I’ll call Eric,  and said “We have new national pricing” and I can  “lower your rate to .5% and save you $1000′s per month.” That was in Eric’s first sentence. I asked and Eric said he was with North American Bancard. The phone number and ID matched up to the company.

Just for the record, North American Bancard is a registered Independent Sales Organization/Merchant Service Provider for HSBC Bank USA,National Association, Buffalo, NY and Wells Fargo Bank, N.A.,Walnut Creek, CA.

I’m not sure what the difference between a broker and an ISO is. Individuals cannot decide they want to be in the merchant services business and then just start accepting contracts. Everyone has to be part of a registered company. But let’s leave that aside.

The biggest savings potential for merchants under the Durbin Amendment is via debit. Merchants can achieve maximum savings only under these conditions:

1. They have a “pass through interchange” price plan that enables the merchant to fully take advantage of the new debit fees.
2. Their processor must pass the savings on to them. Some will, some won’t. It’s entirely up to the processor.
3. The card is swiped- the magnetic data must be read, and the consumer can sign or enter their pin.

Don’t be suckered by misleading sales pitches. What rate was Eric talking about? Effective rate? Rate above interchange? Rate for signature debit?  if you want to save money under the new rules, you need an expert not only in interchange, but in help to convert more sales to lower cost debit. That’s where we come in.

The Dodd-Frank Wall Street Reform and Consumer Protection Act, including the Durbin Amendment, set off a series of changes in the financial world, several with big impacts to businesses. This bulletin reduces hundreds of pages of regulations into a a two page overview. Included are critical excerpts from each regulation, advice, and real world solutions you can use to leverage legislation to your benefit. It answers the questions-  What do I need to know, and how can I use this to improve EBITDA and reduce risk?

This reference guide is targeted primarily towards the needs of businesses that match our current and future client base. Mid to large size retail and card not present business operations including manufacturers, distributers, non-profits, utilities, retailers, and non-grocery, non-fuel entities.

KEY TAKEAWAYS:
• Lower cost debit coming soon will create huge incentive for merchants to drive debit.
• Merchants may steer customers to lower cost payment methods by offering discounts and publicly stating their preference for payment types.
• Merchants may be held criminally liable for identity theft.
• Merchants need to make it easy for customers to opt-out of recurring billing.
• Merchants updating technology should consider the flexibility they’ll have for ongoing regulation changes.

Download PDF 3D Merchant Services Condensed Guide for Merchant Payments Related Legislative Updates 2010, 2011 and to 2012. An apology in advance, it was very difficult to fit and is best viewed on your screen.

Download secondary PDF about some of the solutions mentioned. 3D Merchant Payment Processing Technology to increase debit and other benefits.

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Are you familiar with recent government regulation changes with respect to payment processing? In July 2010, President Obama signed into law the Dodd-Frank Wall Street Reform and Consumer Protection Act. A major element of that is known as the Durbin Amendment. In essence, the government is intervening and creating price controls with regard to payment card transactions.

July 2010- law signed

October 2010- Changes to minimum transaction amount rules in effect. Discount option available to merchants.

July 2011- Dept of Justice settles with Visa and MasterCard over card steering and discounts, specifically addressing compliance with this Act.

October 2011- new debit card interchange standards go into effect. See also Comments for merchants on debit interchange final rule
Final text of Durbin Amendment as contained in the Dodd Frank Act

‘‘SEC. 920. REASONABLE FEES AND RULES FOR PAYMENT CARD TRANSACTIONS.

‘‘(a) REASONABLE INTERCHANGE TRANSACTION FEES FOR ELECTRONIC DEBIT TRANSACTIONS.—

“(1) REGULATORY AUTHORITY OVER INTERCHANGE TRANSACTION FEES.—The Board may prescribe regulations, pursuant to section 553 of title 5, United States Code, regarding any interchange transaction fee that an issuer may receive or charge with respect to an electronic debit transaction, to implement this subsection (including related definitions), and to prevent circumvention or evasion of this subsection.

‘‘(2) REASONABLE INTERCHANGE TRANSACTION FEES.—The amount of any interchange transaction fee that an issuer may receive or charge with respect to an electronic debit transaction shall be reasonable and proportional to the cost incurred by the issuer with respect to the transaction.

‘‘(3) RULEMAKING REQUIRED.—

‘‘(A) IN GENERAL.—The Board shall prescribe regulations in final form not later than 9 months after the date of enactment of the Consumer Financial Protection Act of 2010, to establish standards for assessing whether the amount of any interchange transaction fee described in paragraph (2) is reasonable and proportional to the cost incurred by the issuer with respect to the transaction.

‘‘(B) INFORMATION COLLECTION.—The Board may require any issuer (or agent of an issuer) or payment card network to provide the Board with such information as may be necessary to carry out the provisions of this subsection and the Board, in issuing rules under subparagraph (A) and on at least a bi-annual basis thereafter, shall disclose such aggregate or summary information concerning the costs incurred, and interchange transaction fees charged or received, by issuers or payment card networks in connection with the authorization, clearance or settlement of electronic debit transactions as the Board considers appropriate and in the public interest.

‘‘(4) CONSIDERATIONS; CONSULTATION.—In prescribing regulations under paragraph (3)(A), the Board shall—

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“(A) consider the functional similarity between—

‘‘(i) electronic debit transactions; and ‘‘(ii) checking transactions that are required within the Federal Reserve bank system to clear at par;

‘‘(B) distinguish between—

‘‘(i) the incremental cost incurred by an issuer for the role of the issuer in the authorization, clearance, or settlement of a particular electronic debit transaction, which cost shall be considered under paragraph (2); and

‘‘(ii) other costs incurred by an issuer which are not specific to a particular electronic debit transaction, which costs shall not be considered under paragraph (2); and

‘‘(C) consult, as appropriate, with the Comptroller of the Currency, the Board of Directors of the Federal Deposit Insurance Corporation, the Director of the Office of Thrift Supervision, the National Credit Union Administration Board, the Administrator of the Small Business Administration, and the Director of the Bureau of Consumer Financial Protection.

‘‘(5) ADJUSTMENTS TO INTERCHANGE TRANSACTION FEES FOR FRAUD PREVENTION COSTS.—

‘‘(A) ADJUSTMENTS.—The Board may allow for an adjustment to the fee amount received or charged by an issuer under paragraph 25 (2), if—

‘‘(i) such adjustment is reasonably necessary to make allowance for costs incurred by the issuer in preventing fraud in relation to electronic debit transactions involving that issuer; and

‘‘(ii) the issuer complies with the fraud-related standards established by the Board under subparagraph (B), which standards shall—

‘‘(I) be designed to ensure that any fraud-related adjustment of the issuer is limited to the amount described in clause (i) and takes into account any fraud-related reimbursements (including amounts from charge-backs) received from consumers, merchants, or payment card networks in relation to electronic debit transactions involving the issuer; and

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‘‘(II) require issuers to take effective steps to reduce the occurrence of, and costs from, fraud in relation to electronic debit transactions, including through the development and implementation of cost-effective fraud prevention technology.

‘‘(B) RULEMAKING REQUIRED.—

‘‘(i) IN GENERAL.—The Board shall prescribe regulations in final form not later than 9 months after the date of enactment of the Consumer Financial Protection Act of 2010, to establish standards for making adjustments under this paragraph.

‘‘(ii) FACTORS FOR CONSIDERATION.—In issuing the standards and prescribing regulations under this paragraph, the Board shall consider—

‘‘(I) the nature, type, and occurrence of fraud in electronic debit transactions;

‘‘(II) the extent to which the occurrence of fraud depends on whether authorization in an electronic debit transaction is based on signature, PIN, or other means;

‘‘(III) the available and economical means by which fraud on electronic debit transactions may be reduced;

‘‘(IV) the fraud prevention and data security costs expended by each party involved in electronic debit transactions (including consumers, persons who accept debit cards as a form of payment, financial institutions, retailers and payment card networks);

‘‘(V) the costs of fraudulent transactions absorbed by each party involved in such transactions (including consumers, persons who accept debit cards as a form of payment, financial institutions, retailers and payment card networks);

‘‘(VI) the extent to which interchange transaction fees have in the past reduced or increased incentives for parties involved in electronic debit transactions to reduce fraud on such transactions; and

‘‘(VII) such other factors as the Board considers appropriate. ‘‘(6) EXEMPTION FOR SMALL ISSUERS.—

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‘‘(A) IN GENERAL.—This subsection shall not apply to any issuer that, together with its affiliates, has assets of less than $10,000,000,000, and the Board shall exempt such issuers from regulations prescribed under paragraph (3)(A).

‘‘(B) DEFINITION.—For purposes of this paragraph, the term ‘‘issuer’’ shall be limited to the person holding the asset account that is debited through an electronic debit transaction.

‘‘(7) EXEMPTION FOR GOVERNMENT-ADMINISTERED PAYMENT PROGRAMS AND RELOADABLE PREPAID CARDS.—

‘‘(A) IN GENERAL.—This subsection shall not apply to an interchange transaction fee charged or received with respect to an electronic debit transaction in which a person uses—

‘‘(i) a debit card or general-use prepaid card that has been provided to a person pursuant to a Federal, State or local government- administered payment program, in which the person may only use the debit card or general-use prepaid card to transfer or debit funds, monetary value, or other assets that have been provided pursuant to such program; or

‘‘(ii) a plastic card, payment code, or device that is—

‘‘(I) linked to funds, monetary value, or assets which are purchased or loaded on a prepaid basis;

‘‘(II) not issued or approved for use to access or debit any account held by or for the benefit of the card holder (other than a subaccount or other method of recording or tracking funds purchased or loaded on the card on a prepaid basis);

‘‘(III) redeemable at multiple, naffiliated merchants or service providers, or automated teller machines;

‘‘(IV) used to transfer or debit unds, monetary value, or other assets; and

‘‘(V) reloadable and not marketed or labeled as a gift card or gift certificate.

‘‘(B) EXCEPTION.—Notwithstanding subparagraph (A), after the end of the 1-year period beginning on the effective date provided in paragraph (9) his subsection shall apply to an interchange transaction fee charged or received with respect to an electronic debit transaction described in

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subparagraph (A)(i) in which a person uses a general-use prepaid card, or an electronic debit transaction described in subparagraph (A)(ii), if any of the following fees may be charged to a person with respect to the card:

‘‘(i) A fee for an overdraft, including a shortage of funds or a transaction processed for an amount exceeding the account balance.

‘‘(ii) A fee imposed by the issuer for the first withdrawal per month from an automated teller machine that is part of the issuer’s designated automated teller machine network.

‘‘(C) DEFINITION.—For purposes of subparagraph (B), the term ‘designated automated teller machine network’ means either—

‘‘(i) all automated teller machines identified in the name of the issuer; or

‘‘(ii) any network of automated teller machines identified by the issuer that provides reasonable and convenient access to the issuer’s customers.

‘‘(D) REPORTING.—Beginning 12 months after the date of enactment of the Consumer Financial Protection Act of 2010, the Board shall annually provide a report to the Congress regarding —

‘‘(i) the prevalence of the use of general-use prepaid cards in Federal, State or local government-administered payment programs; and

‘‘(ii) the interchange transaction fees and cardholder fees charged with respect to the use of such general-use prepaid cards.

‘‘(8) REGULATORY AUTHORITY OVER NETWORK FEES.—

‘‘(A) IN GENERAL.—The Board may prescribe regulations, pursuant to section 553 of 22 title 5, United States Code, regarding any network fee.

‘‘(B) LIMITATION.—The authority under subparagraph (A) to prescribe regulations shall be limited to regulations to ensure that—

‘‘(i) a network fee is not used to directly or indirectly compensate an issuer with respect to an electronic debit transaction; and

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‘‘(ii) a network fee is not used to circumvent or evade the restrictions of this subsection and regulations prescribed under such subsection.

‘‘(C) RULEMAKING REQUIRED.—The Board shall prescribe regulations in final form before the end of the 9-month period beginning on the date of the enactment of the Consumer Financial Protection Act of 2010, to carry out the authorities provided under subparagraph (A).

‘‘(9) EFFECTIVE DATE.—This subsection shall take effect at the end of the 12- month period beginning on the date of the enactment of the Consumer Financial Protection Act of 2010.

‘‘(b) LIMITATION ON PAYMENT CARD NETWORK RESTRICTIONS.— ‘‘(1) PROHIBITIONS AGAINST EXCLUSIVITY ARRANGEMENTS.—

‘‘(A) NO EXCLUSIVE NETWORK.—The Board shall, before the end of the 1-year period beginning on the date of the enactment of the Consumer Financial Protection Act of 2010, prescribe regulations providing that an issuer or payment card network shall not directly or through any agent, processor, or licensed member of a payment card network, by contract, requirement, condition, penalty, or otherwise, restrict the number of payment card networks on which an electronic debit transaction may be processed to—

‘‘(i) 1 such network; or

‘‘(ii) 2 or more such networks which are owned, controlled, or otherwise operated by —

‘‘(I) affiliated persons; or

‘‘(II) networks affiliated with such issuer.

‘‘(B) NO ROUTING RESTRICTIONS.—The Board shall, before the end of the 1-year period beginning on the date of the enactment of the Consumer Financial Protection Act of 2010, prescribe regulations providing that an issuer or payment card network shall not, directly or through any agent, processor, or licensed mem ber of the network, by contract, requirement, condition, penalty, or otherwise, inhibit the ability of any person who accepts debit cards for payments to direct the routing of electronic debit transactions for processing over any payment card network that may process such transactions.

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‘‘(2) LIMITATION ON RESTRICTIONS ON OFFERING DISCOUNTS FOR USE OF A FORM OF PAYMENT.—

‘‘(A) IN GENERAL.—A payment card network shall not, directly or through any agent, processor, or licensed member of the network, by contract, requirement, condition, penalty, or otherwise, inhibit the ability of any person to provide a discount or in-kind incentive for payment by the use of cash, checks, debit cards, or credit cards to the extent that—

‘‘(i) in the case of a discount or in kind incentive for payment by the use of debit cards, the discount or in-kind incenttive does not differentiate on the basis of the issuer or the payment card network;

‘‘(ii) in the case of a discount or in-kind incentive for payment by the use of credit cards, the discount or in-kind incentive does not differentiate on the basis of the issuer or the payment card network; and

‘‘(iii) to the extent required by Federal law and applicable State law, such discount or in-kind incentive is offered to all prospective buyers and disclosed clearly and conspicuously.

‘‘(B) LAWFUL DISCOUNTS.—For purposes of this paragraph, the network may not penalize any person for the providing of a discount that is in compliance with Federal law and applicable State law.

‘‘(3) LIMITATION ON RESTRICTIONS ON SETTING TRANSACTION MINIMUMS OR MAXIMUMS.—

‘‘(A) IN GENERAL.—A payment card network shall not, directly or through any agent, processor, or licensed member of the network, by contract, requirement, condition, penalty, or otherwise, inhibit the ability—

‘‘(i) of any person to set a minimum dollar value for the acceptance by that person of credit cards, to the extent that —

‘‘(I) such minimum dollar value does not differentiate between issuers or between payment card networks; and

‘‘(II) such minimum dollar value does not exceed $10.00; or

‘‘(ii) of any Federal agency or institution of higher education to set a maximum dollar value for the acceptance by that Federal agency or institution of higher education of credit cards, to the extent that such maximum dollar value does not differentiate between issuers or between payment card networks.

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‘‘(B) INCREASE IN MINIMUM DOLLAR AMOUNT.—The Board may, by regulation prescribed pursuant to section 553 of title 5, United States Code, increase the amount of the dollar value listed in subparagraph (A)(i)(II).

‘‘(4) RULE OF CONSTRUCTION:.—No provision of this subsection shall be construed to authorizeany person—

‘‘(A) to discriminate between debit cards within a payment card network on the basis of the issuer that issued the debit card; or

‘‘(B) to discriminate between credit cards within a payment card network on the basis of the issuer that issued the credit card.

‘‘(c) DEFINITIONS.—For purposes of this section, the following definitions shall apply:

‘‘(1) AFFILIATE.—The term ‘affiliate’ means any company that controls, is controlled by, or is under common control with another company.

‘‘(2) DEBIT CARD.—The term ‘debit card’— ‘‘(A) means any card, or other payment code or device, issued or approved for use through a payment card network to debit an asset account (regardless of the purpose for which the account is established), whether authorization is based on signature, PIN, or other means;

‘‘(B) includes a general-use prepaid card, as that term is defined in section 915(a)(2)(A); and

‘‘(C) does not include paper checks.

‘‘(3) CREDIT CARD.—The term ‘credit card’ has the same meaning as in section 103 of the Truth in Lending Act.

‘‘(4) DISCOUNT.—The term ‘discount’—

‘‘(A) means a reduction made from the price that customers are informed is the regular price; and

‘‘(B) does not include any means of increasing the price that customers are informed is the regular price.

‘‘(5) ELECTRONIC DEBIT TRANSACTION.—The term ‘electronic debit transaction’ means a transaction in which a person uses a debit card.

‘‘(6) FEDERAL AGENCY.—The term ‘Federal agency’ means—

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‘‘(A) an agency (as defined in section 101of title 31, United States Code); and

‘‘(B) a Government corporation (as defined in section 103 of title 5, United States Code).

‘‘(7) INSTITUTION OF HIGHER EDUCATION.— The term ‘institution of higher education’ has the same meaning as in 101 and 102 of the Higher Education Act of 1965 (20 U.S.C. 1001, 1002).

‘‘(8) INTERCHANGE TRANSACTION FEE.—The term ‘interchange transaction fee’ means any fee established, charged or received by a payment card network for the purpose of compensating an issuer for its involvement in an electronic debit transaction.

‘‘(9) ISSUER.—The term ‘issuer’ means any person who issues a debit card, or credit card, or the agent of such person with respect to such card.

‘‘(10) NETWORK FEE.—The term ‘network fee’ means any fee charged and received by a payment card network with respect to an electronic debit transaction, other than an interchange transaction fee.

‘‘(11) PAYMENT CARD NETWORK.—The term‘payment card network’ means an entity that directly, or through licensed members, processors, or agents, provides the proprietary services, infrastructure, and software that route information and data to conduct debit card or credit card transaction authorization, clearance, and settlement, and that a person uses in order to accept as a form of payment a brand of debit card, credit card or other device that may be used to carry out debit or credit transactions.

‘‘(d) ENFORCEMENT.—

‘‘(1) IN GENERAL.—Compliance with the requirements imposed under this section shall be enforced under section 918.

‘‘(2) EXCEPTION.—Sections 916 and 917 shall not apply with respect to this section or the requirements imposed pursuant to this section.’’.

(b) AMENDMENT TO THE FOOD AND NUTRITION ACT 8 OF 2008.—Section 7(h)(10) of the Food and Nutrition Act of 2008 (7 U.S.C. 2016(h)(10)) is amended to read as follows: ‘‘(10) FEDERAL LAW NOT APPLICABLE.—Section 920 of the Electronic Fund Transfer Act shall not apply to electronic benefit transfer or reimbursement systems under this Act.’’.

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(c) AMENDMENT TO THE FARM SECURITY AND RURAL INVESTMENT ACT OF 2002.—Section 4402 of the Farm Security and Rural Investment Act of 2002 (7 U.S.C. 3007) is amended by adding at the end the following new subsection:

‘‘(f) FEDERAL LAW NOT APPLICABLE.—Section 920 of the Electronic Fund Transfer Act shall not apply to electronic benefit transfer systems established under this section.’’. (d) AMENDMENT TO THE CHILD NUTRITION ACT OF 1966.— Section 11 of the Child Nutrition Act of 1966 (42 U.S.C. 1780) is amended by adding at the end the following:

‘‘(c) FEDERAL LAW NOT APPLICABLE.—Section 920 of the Electronic Fund Transfer Act shall not apply to electronic benefit transfer systems established under this Act or the Richard B. Russell National School Lunch Act (42 U.S.C. 1751 et seq.).’’.

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The new cap on debit fees card issuers may charge is $.21 and 5 basis points according to the Dodd–Frank Wall Street Reform and Consumer Protection Act. Rather than reducing the costs merchants end up paying, the status quo will remain for most merchants, and there even is room to increase rates. By requiring that all providers allow at least two debit network options, the hope is that competition will keep prices down.

Examples of MasterCard interchange rates for signature debit effective April 2011:

Consumer Debit Full UCAF .90% + USD 0.25
Consumer Debit Emerging Markets 0.80% + USD 0.25
Consumer Debit Standard 1.90% + USD 0.25

For the best signature debit the customer is expected to be present, swipe their card, and sign the sales receipt. Debit standard results when the transaction did not meet all the criteria for the lowest rate set by the card issuer. This ‘downgrade’ could be for many reasons, including cashier error.

Pin Debit rates vary, but the most common networks are charging 95 basis points, or .95% and $.20 per transaction. In these transactions, the customer is present, swipes their card, and enters their pin number into the terminal or pinpad.

What will merchants pay under the new regulation? To be eligible for the new rates:
- The debit card must be issued by a bank, together with its affiliates, that has assets of less than $10 billion. A rough estimate is 80% of cards in the marketplace today qualify.
- The debit card must be swiped.
- A signature is required.
- All other criteria for the lowest rate would still apply such as settling the transaction within 24 hours, and authorization and capture must be for the same amount.
- The merchant must have true pass through interchange pricing per schedule A of their merchant agreement.

In addition to lower interchange, the Frank Dodd Act also requires that when a bank issues a credit card, it must have at least two network symbols on the back so that debits can process on two different networks. Theoretically, this is so merchants can benefit from competition and have a lower cost pin debit option. How does the merchant get the lower cost fee if there are two debit networks? The merchant must have these debit card processing technology capabilities:

– It must recognize the type of card when swiped as debit or credit.
– It must interact with a smart system that can identify the two competing network costs.
– It must determine which one will cost the merchant less.
– It must route transaction to the lower cost network.

This cannot be done by the processor. It cannot be done with dial up machines. It cannot be done with over 95% of the equipment on the market today.

It will require a host based solution that can dynamically identify the data being sent, know the costs for every option for the transaction and intelligently make decisions for the merchant. Oh, and make it quick because customers don’t want to wait. This may sound simple, but imagine having to create a database with the identity of every bank card issued (not the individual card owner, but the card issuer). How readily is that information available? It’s not. That’s a primary reason why solutions are not prevalent in the marketplace.

To manage the cost of debit processing, merchants will need to upgrade their technology. There are limited options on the market today. At 3D Merchant Services, we’ve offered customers a solution for several years that accomplishes all the tasks needed. While other vendors will enter the market, CenPOS technology is proven in the marketplace and extremely robust with benefits beyond lowest cost routing. Merchant fees are on a transaction basis.

Here’s how we can empower merchants to make risk and financial based decisions automatically:
- IN addition to meeting all the criteria above, merchants can:
- create rules to send debit transactions to signature

The regulation governs what the card issuers can make. It does not govern what fees merchants pay to their processor. Merchants that are not on pass through pricing will not likely see a decline in their processing fees. Most processors will simply keep the extra money and boost profits.
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