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The FDIC also noted that the CRA requires it to evaluate the credit U.S. Consumers Have Concerns
needs of the communities the institutions serve when considering About Lowering Debit Card
merger applications. Given credit unions are not subject to the
CRA, “transactions involving a credit union may require additional Interchange Fees
information to evaluate the convenience and needs statutory factor,”
the agency said. Most U.S. consumers with an opinion on debit card interchange
fees agree the fees are necessary for fraud prevention efforts, and they
Read more: https://www.fdic.gov/news/press-releases/2024/fdic- would oppose lowering the fees if it meant higher checking account
board-directors-approves-final-statement-policy-bank-merger fees, according to a new survey by Morning Consult and the Bank
Policy Institute.
FDIC, OCC Tighten Policy The Federal Reserve has proposed revising Regulation II to lower

Considerations for Bank Merger debit card interchange fees. The Morning Consult/BPI survey found
Applications that U.S. adults are overwhelmingly satisfied with their debit cards
and regularly use them to make purchases. More than two-thirds
The FDIC and Office of Comptroller of the Currency have issued of respondents (70%) use debit cards at least once a week to make
new policies that expand the factors both will take into consideration purchases, with speed of checkout, convenience and security among
when reviewing bank merger applications, with the OCC the top reasons cited for card use.
eliminating its expedited review process and the use of streamlined Seventy-three percent of respondents with an opinion on interchange
applications.
fees agreed that the fees are necessary to support fraud prevention
The FDIC board voted 3-2 in favor of a final statement on bank measures by banks, according to the survey. Seventy percent of that
merger policy. Among the changes, the policy states that when same group said that lowering interchange fees would only benefit
reviewing a proposed merger’s competitive effects, the agency can large retail chain stores, with 72% opposing lowering the fees if it
consider concentrations on products and services beyond those meant higher checking fees. A further 79% said the fees are fair
based on deposits, such as the volume of small business or residential compared to the benefits that retailers receive from accepting debit
loan originations. It applies additional scrutiny to proposed mergers card payments.
resulting in an institution with $100 billion or more in total assets Read more: https://bpi.com/survey-finds-consumers-value-debit-
and requires public hearings for mergers resulting in an institution card-convenience-and-security-over-government-price-fixing-and-
with more than $50 billion in total assets. It also establishes a policy profits-for-giant-chain-stores/
against banks entering into or enforcing noncompete agreements
with any employee of the divested entity. #BanksNeverAskThat Campaign
One modification from the proposal issued in March is that the final to Encourage Consumers to
document no longer states that the FDIC will penalize applications if
the merger results in a weaker institution from a financial perspective #PracticeSafeChecks
as long as the resulting institution would be financially sound,
FDIC Chairman Martin Gruenberg said. However, it stresses that Registration is open for the 2024 #BanksNeverAskThat anti-
a proposed merger must “better meet the convenience and needs of phishing campaign, which will kick off Oct. 1. New this year is the
the community to be served than would occur absent the merger in #PracticeSafeChecks campaign aimed at preventing check fraud.
order for FDIC staff to find favorably on this factor,” he added. Registered banks will receive immediate access to materials to start
planning their campaigns ahead of the campaign's launch.
The two Republican board members voted against the statement,
saying it would make the merger application longer and more Read more: https://www.aba.com/advocacy/community-
difficult. “I continue to believe the revised approach to the programs/banksneveraskthat
competition factor will add considerable unpredictability, by
deemphasizing the use of [Herfindahl-Hirschman Index] thresholds, FDIC Proposes New
long a predictable proxy for concentrations and by elevating Recordkeeping Requirements for
consideration of ‘concentrations in any specific products or customer Bank-Fintech Partnerships
segments,’” FDIC Vice Chairman Travis Hill said.
Read more: https://www.fdic.gov/news/press-releases/2024/fdic- The FDIC board is advancing a proposed rule to establish new
board-directors-approves-final-statement-policy-bank-merger recordkeeping requirements for banks that enter into arrangements
with third-party fintech firms to provide deposit products and
services. According to the agency, the rule would require FDIC-

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