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    SmartBrief enables case brief popups that define Key Terms, Doctrines, Acts, Statutes, Amendments and Treatises used in this case.

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    Banking Law Keyed to Barr, 3rd Ed.

    National Association of Convenience Stores v. Board of Governors of the Federal Reserve System

    Citation:

    958 F. Supp. 2d 85 (2013)

    Facts

    In 2010, Congress passed the Durbin Amendment to address rising debit card fees by requiring that interchange fees be “reasonable and proportional” to the issuer’s costs and by prohibiting network exclusivity arrangements. The Amendment directed the Board to establish standards for determining whether interchange fees meet this requirement, specifically instructing the Board to consider only “incremental costs” incurred by issuers for authorization, clearance, and settlement (ACS) of transactions, while excluding other costs. The Board initially proposed limiting allowable costs to variable ACS costs, with a cap of 12 cents per transaction. However, in its Final Rule, the Board significantly expanded the allowable costs to include fixed costs, transaction monitoring costs, fraud losses, and network processing fees, resulting in a higher cap of 21 cents plus 0.05% of the transaction value. For network non-exclusivity, the Board required only that each debit card be able to function on at least two unaffiliated networks, rather than requiring multiple network options for each type of transaction. Plaintiffs challenged both aspects of the Final Rule as exceeding the Board’s statutory authority.

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    National Association of Convenience Stores v. Board of Governors of the Federal Reserve System