FR3064_20250116_omb

Supporting Statement for the
Interchange Transaction Fees Survey
(FR 3064; OMB No. 7100-0344)
Summary
The Board of Governors of the Federal Reserve System (Board), under authority
delegated by the Office of Management and Budget (OMB), has extended for three years,
without revision, the Interchange Transaction Fees Survey (FR 3064; OMB No. 7100-0344).
This information collection comprises the following reports:
• Debit Card Issuer Survey (FR 3064a) collects data from issuers of debit cards (including
general-use prepaid cards) that, together with their affiliates, have assets of $10 billion or
more, including information regarding the volume and value of debit card transactions;
chargebacks and returns; costs of authorization, clearance, and settlement of debit card
transactions; other costs incurred in connection with particular debit card transactions;
fraud prevention costs and fraud losses; and interchange fee revenue.1
• Payment Card Network Survey (FR 3064b) collects data from payment card networks,
including the volume and value of debit card transactions; interchange fees; network fees;
and payments and incentives paid by networks to acquirers, merchants, and issuers.2
The data from the FR 3064a and FR 3064b are used to fulfill a statutory requirement that
the Board disclose certain information regarding debit card transactions on a biennial basis.3 In
addition, the Board uses data from the Payment Card Network Survey (FR 3064b) to publicly
report on an annual basis the extent to which networks have established separate interchange fees
for exempt and covered issuers.4
The estimated total annual burden for the FR 3064 is 86,085 hours. The forms and
instructions are available on the Board’s public website at
https://www.federalreserve.gov/paymentsystems/regii-data-collections.htm.
Background and Justification
Section 920(a)(3) of the Electronic Fund Transfer Act, as added by section 1075(a)(3) of
the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), provides
that the Board shall, on at least a biennial basis, 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 debit card transactions as the Board considers
appropriate and in the public interest.5 In addition, when the Board adopted Regulation II - Debit
Card Interchange Fees and Routing (12 CFR Part 235), the Board stated that, in order to monitor
the effectiveness of the small-issuer exemption from the interchange fee standards, it planned to
1

See 12 CFR 235.2(k) for the definition of Issuer.
See 12 CFR 235.2(m) for the definition of Payment card network.
3
See 12 U.S.C. § 1693o-2(a)(3)(B). The Board’s biennial reports are available at
https://www.federalreserve.gov/paymentsystems/regii-data-collections.htm.
4
See Average Debit Card Interchange Fee by Payment Card Network
https://www.federalreserve.gov/paymentsystems/regii-average-interchange-fee.htm.
5
See 15 U.S.C. § 1693o-2(a)(3)(B).
2

collect information from payment card networks annually and planned to publish annually a list
of the average interchange fees each network provides to its covered and exempt issuers.6 This
information is not available from other sources. Without the FR 3064, the Board would be
unable to fulfill its statutory obligations.
Description of Information Collection
The FR 3064 comprises two surveys: (1) Debit Card Issuer Survey (FR 3064a) and
(2) Payment Card Network Survey (FR 3064b). A general description of these surveys is
provided below. The Board accepts electronic submissions from respondents using a dedicated
portal for each data collection. Each respondent has access to unique and confidential access
credentials to submit data to the Board.
Debit Card Issuer Survey (FR 3064a)
The Debit Card Issuer Survey is required for each debit card issuer that, together with its
affiliates, has assets of $10 billion or more (covered issuers). In general, the Debit Card Issuer
Survey collects information on two types of debit card programs and transactions: dual-message
and single-message.7 Both programs include general-use prepaid card transactions. The survey
requests information on accounts and cards associated with accounts domiciled in the United
States, the District of Columbia, and U.S. territories.8 The Debit Card Issuer Survey comprises
five sections.
I. Respondent Information: Respondents provide the name of the debit card issuer
covered in the response and the contact person(s)’s name, e-mail, and phone number.
II. Information for all Debit Card Transactions (including general-use prepaid card
transactions): Respondents report summary information for debit card (including
general-use prepaid card) transaction volume and value; chargebacks to and returns from
acquirers; costs of authorization, clearance, and settlement; other costs incurred in
connection with particular debit card transactions that are not authorization, clearance,
and settlement costs; costs for fraud prevention and data security; fraudulent transactions
and fraud losses; and interchange fee revenue.9
III. Information for Single-Message Debit Card Transactions (excluding general-use
prepaid card transactions): Respondents submit data for the same set of questions
asked in Section II, above, for single-message debit card programs, excluding general-use
prepaid cards.
6

See 76 FR 43394, 43436 (July 20, 2011).
In dual-message transactions, authorization information is carried in one message and clearing information is
carried in a separate message. In single-message transactions, authorization and clearing information is carried in
one message. General-use prepaid card transactions use either communication method (although dual-message
transactions are more common). General-use prepaid cards can be reloadable or non-reloadable.
8
U.S. territories include American Samoa, Federal States of Micronesia, Guam, Midway Islands, Northern Mariana
Islands, Puerto Rico, Republic of Palau, Republic of the Marshall Islands, and U.S. Virgin Islands.
9
The list of fraud prevention activities (such as transaction monitoring, merchant blocking, data security, PIN
customization, and other) may be updated over time based on “other” activities reported.
7

2

IV. Information for Dual-Message Debit Card Transactions (excluding general-use
prepaid card transactions): Respondents submit data for the same set of questions
asked in Section II, above, for dual-message debit card programs, excluding general-use
prepaid cards.
V. Information for General-Use Prepaid Card Transactions: Respondents submit data
for largely the same set of questions asked in Section II, above, for general-use prepaid
card transactions. Questions related to general-use prepaid transactions are modified to
include a breakout of single-message and dual-message transactions.
Payment Card Network Survey (FR 3064b)
The Payment Card Network Survey is required for all entities that are considered
“payment card networks” under Regulation II. The Payment Card Network Survey requests
information on domestic debit card transactions (i.e., those in which both the merchant and
account debited are located in the United States). Regulation II requires each payment card
network to submit information about debit card (including general-use prepaid card) transactions
in a form prescribed by the Board.10 The Payment Card Network Survey comprises two
sections.11
I. Respondent Information: Respondents provide the network covered in this response
and the contact person(s)’s name, e-mail, and phone number. Respondents also report
whether the payment card network is a single-message or dual-message network. In the
event that a network processes both single-message and dual-message transactions, the
network must complete a survey for each type of transaction.
II. Information on Debit Card Transactions (including general-use prepaid card
transactions): Respondents report summary information for the volume and value of all
debit card transactions; volume and value for chargebacks to and returns from acquirers;
the volume and value of card-present and card-not-present transactions; the volume and
value of transactions involving exempt and non-exempt issuers; the volume and value of
transactions involving exempt and non-exempt general-use prepaid card transactions; the
value of interchange fees for all transactions, exempt/non-exempt issuers, and exempt
general-use prepaid card transactions; the value of network fees; and payments and
incentives paid by networks to acquirers, merchants, and issuers.
The Board understands that respondents use information technology to comply with these
provisions.
Respondent Panel
The FR 3064 panel comprises debit card issuers and payment card networks.

10

See 12 CFR 235.8.
Entities that have both single-message and dual-message networks are asked to report data for each program
separately.
11

3

Frequency and Time Schedule
The FR 3064 surveys are submitted annually by May 1. Data are as of December 31 of
the previous year.
Public Availability of Data
The Board is required to disclose, as appropriate and in the public interest, aggregate or
summary information concerning the costs incurred and interchange fees charged or received by
issuers and payment card networks on a biennial basis. In addition, the Board previously
announced that it will disclose information on payment card network interchange fees on an
annual basis. The Board targets a publication of the Payment Card Network Survey results and
the Debit Card Issuer Survey results by, respectively, the end of the third and fourth quarter of
every survey year.
Legal Status
The FR 3064a and FR 3064b are authorized by section 920(a) of the Electronic Fund
Transfer Act, as amended by section 1075(a) of the Dodd-Frank Act (12 U.S.C. § 1693o-2). This
provision requires the Board, at least once every two years,12 to disclose 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.13 It also provides the Board with authority to require issuers and payment card networks
to provide information to enable the Board to carry out the provisions of the subsection. The
FR 3064a and FR 3064b are mandatory.
The Board is required to release aggregate information from responses to the FR 3064a
and FR 3064b. The Board additionally releases, at the network level, the percentage of total
number of transactions, the percentage of total value of transactions, and the average transaction
value for exempt and non-exempt issuers obtained on the FR 3064b because it can be calculated
based on information the Board already releases and may be useful to issuers, merchants, and
policymakers in choosing payment card networks and assessing the effects of interchange
regulations. The information contained in individual responses to the FR 3064a and FR 3064b is
nonpublic commercial or financial information, which is both customarily and actually treated
as private by the respondent. The Board therefore keeps such information confidential pursuant
to exemption 4 of the Freedom of Information Act (FOIA) (5 U.S.C. § 552(b)(4)).
Consultation Outside the Agency
There has been no consultation outside the Federal Reserve System.

12

The subsection refers to bi-annual disclosures and the Board interprets this to mean once every two years. See 76
FR 43458 (July 20, 2011).
13
15 U.S.C. § 1693o-2(a)(3)(B).

4

Public Comments14
On May 29, 2025, the Board published an initial notice in the Federal Register (90 FR
22726) requesting public comment for 60 days on the extension, without revision, of the
FR 3064. The comment period for this notice expired on July 28, 2025. The Board received four
comments; two from banking industry trade associations, one from a bank holding company, and
one from a payment card network.15 All commenters recommended changes to the Debit Card
Issuer Survey (FR 3064a) (the DCI survey), and two recommended changes to the Payment Card
Network Survey (FR 3064b) (the PCN survey). The Board adopted the extension, without
revision, of the FR 3064 as originally proposed. On January 12, 2026, the Board published a
final notice in the Federal Register (91 FR 1180).
Detailed Discussion of Public Comments
I. DCI Survey
Comments on the DCI survey broadly addressed the following: (A) collecting
information on new categories of costs, as well as a detailed list of line items relating to both
existing and new cost categories, (B) making certain structural changes to the DCI survey,
including with respect to routing methods and fraud, and (C) certain other matters that pertain to
the substance of Regulation II or otherwise pertain to the DCI survey only indirectly.
A. Costs Included in the DCI Survey
1. Summary of Comments
Three commenters asserted that the information collected through the DCI survey is too
limited and thus provides an incomplete picture of costs incurred by debit card issuers.
Commenters proposed that the Board collect data on certain new categories of costs not currently
included in the DCI survey, such as: international fraud losses; card maintenance costs; program
setup, infrastructure, and account maintenance costs; research, development, and technology
costs; compliance and regulatory costs; periodic statement and account information costs;
consumer impact metrics; and an open-ended category of “other” costs.
Two commenters suggested a list of about 40 specific line items that relate to both
existing and new cost categories. With respect to existing cost categories, commenters suggested
14

On November 14, 2023, the Board published a notice of proposed rulemaking in which the Board proposed to
update Regulation II’s interchange fee cap and to update the interchange fee cap every other year going forward by
directly linking the interchange fee cap to data from the Debit Card Issuer Survey (the Interchange Fee Cap
Proposal). See 88 FR 78100 (November 14, 2023). In response to the Interchange Fee Cap Proposal, the Board
received a variety of comments regarding the Debit Card Issuer Survey and the data collected using the Debit Card
Issuer Survey, and those comments are being considered in connection with the Interchange Fee Cap Proposal. The
current proposed extension is independent from the Interchange Fee Cap Proposal and will allow the Board to
continue using the Debit Card Issuer Survey and Payment Card Network Survey beyond their current expiration date
of January 31, 2026.
15
The comment letter from the bank holding company endorsed one of the trade association letters. They are treated
as two separate comment letters herein.

5

line items related to fraud losses and fraud-prevention costs; transaction processing and network
costs; cardholder inquiry costs; cardholder rewards costs; capital and fixed costs; and third-party
service provider costs.16 With respect to new cost categories, commenters suggested line items
related to card maintenance costs; program setup, infrastructure, and account maintenance costs;
research, development, and technology costs; compliance and regulatory costs; periodic
statement and account information costs; and “other” costs.17
Four commenters raised issues related to technology-specific costs. Three commenters
recommended including a new cost category for costs related to tokenization and digital wallets,
noting the increased popularity of digital wallets. One commenter suggested edits to the
definition of “third-party processing fees” to expressly include fees related to third-party service
providers that are digital wallet operators; the same commenter also suggested edits to the
definition of “transaction monitoring costs” to expressly include, in addition to neural networks
and fraud-scoring systems, a catchall reference to other technologies. The commenter also
suggested including an additional list of examples to the definition of “total fraud-prevention and
data-security costs,” including EMV and contactless card technology, tokenization technology,
machine learning and artificial intelligence, technology to allow customers to enable or disable
their debit cards, technologies for cardholder authentication, and others.
Two commenters expressed the view that the DCI survey is narrowly focused on costs
incurred by issuers and suggested that the Board should also capture the costs incurred by other
parties to debit card transactions. With respect to consumers, commenters noted that the DCI
survey is not an accurate reflection of consumer costs and suggested that the Board collect data
on changes in the availability and terms of free checking accounts and debit card rewards, and
changes in consumer fees related to debit card use. With respect to merchants, commenters stated
that payment processing fees have emerged as a leading cost to merchants, encompassing a
significant portion of fees paid by merchants to accept debit card transactions, and suggested that
the DCI survey capture the third-party processor costs incurred by merchants.

16

For example, with respect to fraud losses and fraud prevention costs, commenters proposed line items for fraudprevention costs, fraud detection and monitoring, fraud losses, costs of developing and implementing anti-fraud
technologies, data breach-related losses, and costs of fraud monitoring required to facilitate debit card issuing
activities. With respect to transaction processing and network costs, commenters proposed line items for
authorization costs, costs of transaction monitoring during authorization, clearing and settlement costs, network fees,
costs of posting transactions to customer accounts, costs of storage and recordkeeping of transaction information,
and transaction security costs.
17
For example, with respect to program setup, infrastructure, and account maintenance costs, commenters proposed
line items for costs of agreements with debit card networks, costs of development and distribution of account terms
and required disclosures, costs of system setup for transaction processing, account setup costs specific to debit card
functionality, account maintenance costs related to debit card programs, and funds loading costs. With respect to
compliance and regulatory costs, commenters proposed line items for compliance costs related to debit transactions
and costs of legal, audit, and regulatory reporting functions specific to debit cards. With respect to periodic
statement and account information costs, commenters proposed line items for costs of providing transaction details
on paper or electronic statements and costs of online access to account and transaction information for cardholders.

6

2. Response
The Board has determined to retain the costs included in the DCI survey without
change.18 The categories of costs collected through the DCI survey generally comprise those
costs the Board considered in connection with the adoption of the interchange fee cap in the
Board’s Regulation II (12 CFR Part 235), but also include certain additional costs that provide
broader context for costs incurred by issuers in the course of effecting debit card transactions.19
The Board believes that the costs currently included in the DCI survey remain sufficient to allow
the Board to administer Regulation II, as adopted, and release summary and aggregate
information as appropriate in the public interest.20 Further, the Board does not believe that the
increased burden on respondents of responding to a large number of additional items is necessary
for the proper performance of these statutory functions. Some new cost categories suggested by
commenters (such as account maintenance costs, regulatory compliance costs, and periodic
statement and account information costs), as well as specific line items (such as development and
distribution of account terms and required disclosures, costs of legal, audit, and regulatory
reporting, providing transaction details on paper or electronic statements, and online access to
account and transaction information for cardholders), include costs that are not incurred by
issuers in the course of effecting debit card transactions, as discussed in the Adopting Release
issued by the Board in 2011.21 Other new cost categories suggested by commenters (such as
consumer and merchant costs), as well as specific line items (such as the availability and terms
of free checking accounts), are not incurred by debit card issuers at all or are not incurred by
banks in their capacity as debit card issuers.22 In addition, some costs may or may not be
subcategories of existing costs, and it is not clear whether all costs are mutually exclusive or how
they would be defined.23
With respect to technology-specific comments, the Board also does not believe it is
necessary to add a new line item for tokenization and digital wallet costs. However, the Board
believes that it is appropriate to clarify that the DCI survey is intended to be technology neutral.
18

The Board discussed costs included and not included in establishing the interchange fee cap when the Board
adopted Regulation II in 2011. See 76 FR 43394, 43427-31 (July 20, 2011) (the Adopting Release). The Board does
not express any additional views on which costs must, may, or may not be considered by the Board in establishing
interchange fee standards.
19
Since the Board’s initial 2010 voluntary survey of large debit card issuers (collecting information regarding
transactions performed in 2009), the Board has collected data on cardholder rewards, non-sufficient funds handling,
and cardholder inquiries, none of which costs the Board considered when establishing the interchange fee cap.
Starting with the 2011 DCI survey, the Board included the subset of customer service costs associated with
cardholder inquiries regarding particular debit card transactions. 76 FR 79184 (December 21, 2011).
20
The Board is required by statute to (1) prescribe interchange fee standards and (2) on at least a bi-annual basis,
disclose such aggregate or summary information concerning the costs incurred, and interchange transaction fees
charged or received, by debit card issuers in connection with the authorization, clearance, or settlement (ACS) of
debit card transactions as the Board considers appropriate and in the public interest. See 15 USC 1693o-2(a)(3).
21
See Adopting release at 43428.
22
The Board has statutory authority to collect information from debit card issuers and payment card networks. With
respect to debit card issuers and payment card networks, the Board’s statutory authority relates to costs incurred, and
interchange fees charged or received, by issuers or payment card networks in connection with the ACS of electronic
debit transactions. See 15 USC 1693o-2(a)(3)(B).
23
Two commenters noted that banking industry trade associations collect data on costs not included in the DCI
survey, but they do not indicate how the trade associations define those costs or the entities from whom they collect
those data.

7

So long as the costs incurred by a debit card issuer associated with a particular technology fall
within the scope of a question on the DCI survey, those technology costs are already reportable,
regardless of the technology involved. For example, although the definition of “transactions
monitoring costs” refers specifically to the costs of neural networks and fraud-risk scoring
systems as examples, those examples are not intended to be limiting so long as the cost otherwise
falls within the definition of transactions monitoring costs. Similarly, costs associated with
tokenization and digital wallets are already reportable so long as they fall within the scope of a
question in the DCI survey. To avoid any confusion with respect to the definition of transactions
monitoring costs, the Board has clarified in the instructions to the DCI survey that transactions
monitoring costs include, but are not limited to, the costs of neural networks and fraud-risk
scoring.
B. Structural Changes to the DCI Survey
1. Summary of Comments
Three commenters addressed ways in which the Board could restructure aspects of the
DCI survey. One commenter asked the Board to remove Sections III and IV of the DCI survey,
which require issuers to distinguish between single-message (SM) and dual-message (DM) debit
card transactions, respectively. The commenter asserted that Sections III and IV impose burden
on debit card issuers but do not provide actionable insights aligned with the survey’s goals. The
commenter suggested that the Board instead distinguish between “legacy four-party systems”
and “alternative networks” and collect only volume and transaction data specific to routing over
alternative networks (regardless of message format).
One commenter suggested that the Board eliminate the separate collection of volume and
value data for card-present (CP) and card-not-present (CNP) transactions. The commenter stated
that the distinction between CP and CNP transactions no longer reliably reflects ACS costs nor
serves as an accurate proxy for routing options. The commenter explained that CP transactions
were traditionally associated with magnetic stripe and chip card use, whereas CNP transactions
were typically key-entered and associated with catalog and phone purchases, but that
transactions today defy CP and CNP categories. The commenter further explained that, today,
card entry can include magnetic stripe, chip, manual key entry, card-on-file, and tokenization. It
also notes that the expansion of PINless debit has made it possible to route CNP transactions
through payment card networks that traditionally required a PIN. Given the change in the
payments landscape and the fact that a single interchange fee cap applies to all transaction types,
the commenter argued that it is unnecessary to split debit card data by CP and CNP.
One commenter addressed the DCI survey’s reporting requirements for fraudulent debit
card transactions. The commenter asserted that requiring issuers to separately report information
for different fraud types does not provide practical utility in relation to routing.24 In addition, the
commenter stated that many community banks do not have sufficient access to granular data to
report the specified subcategories. The commenter also noted that the term CNP is now
increasingly obsolete, that some categories may not be mutually exclusive, and that the
24

Currently the DCI survey requires debit card issuers to report fraud data according to the following categories:
(1) all fraudulent transactions, (2) CNP fraud, (3) counterfeit fraud, (4) lost and stolen card fraud, and (5) other.

8

subcategory for counterfeit fraud is no longer necessary in light of the widespread adoption of
EMV chip technology. As an alternative, the commenter encouraged the Board to align the
categories of fraud on the DCI survey with the Federal Reserve’s FraudClassifierSM model.25
One commenter requested that the Board eliminate a requirement to report in-house costs
as a subset of a debit card issuer’s ACS costs.26 The commenter stated that community banks
overwhelmingly rely on core processors for data storage and reporting and that, as a result, it is
difficult for community banks to identify in-house processing costs. The commenter also stated
that the instructions to the DCI survey for calculating in-house costs do not align with how
community banks record or account for operational expenses and that they unable to isolate inhouse costs.
2. Response
The Board has determined that it will retain Sections III and IV of the DCI survey
(requiring issuers to separately report information for SM and DM transactions) and continue to
require separate reporting of volume and value for CP and CNP transactions. With respect to the
specific suggestion that the Board replace SM and DM with alternative and legacy networks, the
Board believes it is appropriate to use neutral terms to distinguish between transaction types and
that many networks are capable of processing both SM and DM transactions. With respect to the
suggestion that certain transactions defy CP and CNP categories, the Board understands that
networks continue to distinguish between CP and CNP transactions and believes that the
definitions of “card-present transaction” and “card-not-present transaction” in the DCI survey
remain clear for the vast majority of transactions.
More broadly, the Board believes that there continues to be value to the Board, Congress,
and the broader public in collecting and reporting on data specific to SM and DM transactions
and CP and CNP transactions. As shown in the Board’s reports, the data show significant
differences between SM and DM transactions across a variety of metrics, such as volumes and
values, interchange fees, incentives, network fees, and fraud. The reports also show meaningful
differences between CP and CNP transactions. The Board believes that not reporting these
distinctions would deprive the public of information regarding a significant feature of the debit
card market. At a minimum, the Board believes that, in the event the Board were to consider
future streamlining of the survey to eliminate the distinction between SM and DM transactions
and CP and CNP transactions or different ways to categorize transactions altogether, it would be
important to solicit feedback from a broader range of stakeholders on those specific changes.
In addition, data regarding SM and DM transactions and CP and CNP transactions
provided the Board with insight into gaps in merchant routing choice for CNP transactions. This
25

The FraudClassifier model includes categories for fraud authorized by the defrauded party (which is not collected
through the DCI survey) and unauthorized fraud (which is collected through the DCI survey). Within the category of
unauthorized fraud, the FraudClassifier model distinguishes between fraud involving compromised credentials,
impersonation of an authorized party, physical alteration, digital payment, and physical forgery/counterfeit. See
About the FraudClassifier Model | FedPayments Improvement, available at
https://fedpaymentsimprovement.org/strategic-initiatives/payments-security/fraudclassifier-model/.
26
The DCI survey requires debit card issuers to separate authorization, clearance, and settlement costs into (1) inhouse costs, (2) third-party processing fees, and (3) network processing fees.

9

information prompted the Board to amend Regulation II in 2022 to specify that the requirement
that each debit card transaction must be able to be processed on at least two unaffiliated payment
card networks applies to CNP transactions, and clarify the requirement that debit card issuers
ensure that at least two unaffiliated networks have been enabled to process a debit card
transaction.27 Continued collection of this data will permit the Board to monitor changes made
by debit card issuers in response to these routing amendments.
With respect to fraud, the current subcategories continue to assist the Board in monitoring
and reporting on trends in debit card fraud. Although one commenter stated that certain fraud
categories are of diminished value, data from the most recent bi-annual report show that each of
counterfeit, CNP, and lost and stolen card fraud continues to be a significant source of fraud and
that the distribution of fraud across those account types differs between SM and DM
transactions.28 The Board believes that not reporting on different types of fraud would deprive
the public of information regarding an important aspect of the debit card market. In addition,
while the Board recognizes that some issuers may have difficulty obtaining the data necessary to
accurately report data on different subcategories of fraud, the typical issuer does not appear to
consistently experience these issues. The Board also recognizes that there are instances in which
fraud may be difficult to classify under a single category. As noted in the instructions to the DCI
survey, a debit card issuer may report in a manner consistent with the way that the issuer
categorizes fraud losses.
The Board appreciates comments that the Board should update the DCI survey to align
with the FraudClassifier model, but believes it is premature to revisit the subcategories included
in the DCI survey. On June 20, 2025, the Board, Office of the Comptroller of the Currency, and
Federal Deposit Insurance Corporation published a request for information (RFI) on potential
actions to address payments fraud.29 The RFI, which focused on check, automated clearing
house, wire, and instant payments fraud, includes a section on payments fraud data collection
and information sharing, in which the agencies note that standardizing payments fraud data
collection, along with further information sharing, could provide a more comprehensive
understanding of the prevalence and impact of payments fraud. In the RFI, the agencies also
asked a number of questions regarding payments fraud data, including on how data collection
could be improved and whether the Federal Reserve System could better leverage or improve the
FraudClassifier and ScamClassifier™ models.30 The Board is carefully reviewing comments
received on the RFI, and, although the RFI did not focus on debit card fraud, responses to the
RFI may inform potential future changes to how debit card fraud data is collected through the
DCI survey. In addition, to the extent that the Board does, in the future, consider new
subcategorization for fraud for purposes of the DCI survey, the Board believes that such a
proposal would benefit from public comment on potential changes in this area.
With respect to in-house costs, the Board has determined to retain the breakdown of ACS
costs by in-house costs, third-party processing fees, and network processing fees. As with
27

See generally 87 FR 61217 (October 11, 2022).
See 2021 Interchange Fee Revenue, Covered Issuer Cost, and Covered Issuer and Merchant Fraud Loss Related to
Debit Card Transactions (October 2023).
29
90 FR 26293 (June 20, 2025). The comment period ended on September 18, 2025.
30
Id. at 26297.
28

10

subcategories of fraud costs, the Board recognizes that some issuers may have difficulty
obtaining the data necessary to accurately report data on in-house costs, but the typical issuer
does not appear to experience these issues. Further, the Board uses this data to report information
on in-house costs, third-party processing fees, and network fees across low-, mid-, and highvolume issuers (including as a percentage of total ACS costs and on a per-transaction basis). The
Board notes that there are different ways in which debit card issuers process transactions and that
not reporting these distinctions would deprive the public of information regarding a significant
feature of the debit card market. In addition, eliminating a cost breakdown for in-house costs
would not eliminate the need for debit card issuers to identify and report those costs as part of
their overall ACS costs.
C. Other Matters
The Board received a number of comments on matters that either do not pertain to the
DCI survey or that involve the DCI survey only insofar they involve the substance of
Regulation II itself. Comments in this category include comments on the merits of Regulation II
and the statute pursuant to which the Board adopted Regulation II; comments regarding the costs
that the Board must or should consider when establishing interchange fee standards; comments
regarding the publication date of the 2023 data previously collected by the Board;31 and
comments recommending publication of information regarding the number and completeness of
responses to the DCI survey. The Board is not addressing these out-of-scope comments at this
time.
One commenter asked the Board to update the instructions to the DCI survey to clarify
what it means for a merchant to be located in the United States (for example, in the context of
online transactions). The Board does not believe it would be appropriate to use the instructions to
the DCI survey to address this issue because whether a merchant is located in the United States
relates not only to the survey but also to whether Regulation II applies to a particular transaction.
II. PCN Survey
1. Summary of Comments
Two commenters provided comments with respect to the PCN survey. One commenter
expressed support for the collection of data from small issuers through payment card networks.32
The commenter also generally stated that many of its comments to the DCI survey also applied
to the PCN survey, likely including the commenter’s suggestion that the Board eliminate the
distinction between CP and CNP transactions and SM and DM networks.
One commenter recommended reducing the frequency of the PCN survey, from every
year to every two years. The commenter noted that annual reporting is no longer needed to
31

The Board intends to publish the report on the 2023 data by the end of 2025.
When the Board adopted the interchange fee cap in 2011, the Board stated that the Board was taking steps to
allow the Board to monitor and report to Congress on the effectiveness of the small issuer exemption, including by
surveying payment card networks annually and publishing annually a list of the average interchange fees each
network provides to covered issuers and exempt issuers. Adopting Release at 43436.
32

11

achieve the Board’s original purpose for requiring the PCN survey annually and that the
commenter estimated that it takes at least 270 hours to complete the survey.
One commenter asked the Board to expand the reporting panel for the PCN survey to
include “payment facilitators.”33 The commenter argued that payment facilitators fall within the
definition of payment card network in Regulation II and stated that payment facilitators play a
critical role in the payment ecosystem but are not part of the reporting panel.
2. Response
With respect to the distinction between CP and CNP transactions and SM and DM
networks, the Board believes that there continues to be value in collecting data specific to CP
and CNP transactions and SM and DM networks, as discussed above.
With respect to the burden on respondents of responding to the PCN survey, the Board
appreciates feedback on the number of hours it takes to complete the PCN survey each year. The
Board’s burden calculations reflect an estimate of the average burden on respondents, and the
Board may consider updating its current estimate of average burden if additional respondents
comment on its accuracy in the future.
In addition, with respect to the frequency of the PCN survey, the Board continues to
believe that annual reporting is useful in connection with monitoring the effectiveness of
Regulation II’s small issuer exception at this time. Notably, in recent years, the average
interchange fee received for exempt transactions has increased materially relative to the average
interchange fee received for covered transactions, and the PCN survey is the Board’s only source
of this data.34 However, the Board acknowledges the effort spent by payment card networks to
complete the PCN survey annually. The Board may revisit the frequency of the survey in the
future; if the Board does revisit the issue, the Board would intend to seek public comment from
various stakeholders.
Finally, the Board has determined not to expressly state in the survey instrument that
payment facilitators are required to complete the PCN survey. Whether or not an entity is
required to complete the PCN survey is determined by whether the entity is a “payment card
network” as defined in Regulation II (which definition largely reflects the statutory definition
and has been in place since 2011) and clarified in the Official Board Commentary on
Regulation II.35 Any entity that fits within this definition is a “payment card network” for the
purposes of Regulation II and is responsible for fulfilling the requirements applicable to payment
card networks set forth in Regulation II, including the mandatory reporting through the PCN
survey. The Board does not believe that the PCN survey is the appropriate context for identifying
particular entities or types of entities that meet the definition of “payment card network” for
33

The commenter defined “payment facilitator” as an entity that offers proprietary services and technological
infrastructure to route transactions and settle funds and charge merchants for these services.
34
See Federal Reserve Board, Regulation II (Debit Card Interchange Fees and Routing): Average Debit Card
Interchange Fee by Payment Card Network (2024), https://www.federalreserve.gov/paymentsystems/regii-averageinterchange-fee.htm.
35
See 12 CFR 235.2(m); 12 CFR Part 235 Appendix A, § 235.2(m).

12

purposes of Regulation II, and the Board expresses no view as to whether the particular payment
facilitators referred to by the commenter are in fact payment card networks.
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3064 is 86,085
hours. The Board estimates that there are 531 chartered institutions that, together with affiliates,
have assets of $10 billion or more and that may issue debit cards.36 In addition, the Board
estimates that there are 15 payment card networks that process electronic debit transactions.37
This represents the entire universe of institutions that issue debit cards and of payment card
networks identified via the National Information Center database. The estimated average hours
per response reflects previous feedback on the surveys received from public comments. These
reporting requirements represent approximately 1.2 percent of the Board’s total paperwork
burden.
Estimated
number of
respondents38

FR 3064
FR 3064a
FR 3064b

531
15

Estimated
Estimated
Estimated
annual
average hours annual burden
frequency per response
hours
1
1

160
75

Total

84,960
1,125
86,085

The estimated total annual cost to the public for the FR 3064 is $6,211,033.39
Sensitive Questions
This information collection contains no questions of a sensitive nature, as defined by
OMB guidelines.

36

See https://www.federalreserve.gov/paymentsystems/regii-interchange-fee-standards.htm for a list of institutions
that are known to be non-exempt.
37
This estimate is based on payment card networks known to process electronic debit transactions and responses to
the payment card network data collection for calendar year 2024. See
https://www.federalreserve.gov/paymentsystems/regii-average-interchange-fee.htm for a list of payment card
networks.
38
Of these respondents, none are considered small entities as defined by the Small Business Administration (i.e.,
entities with less than $850 million in total assets). Size standards effective March 17, 2023. See
https://www.sba.gov/document/support-table-size-standards.
39
Total cost to the responding public is estimated using the following formula: total burden hours, multiplied by the
cost of staffing, where the cost of staffing is calculated as a percent of time for each occupational group multiplied
by the group’s hourly rate and then summed (30% Office & Administrative Support at $24, 45% Financial
Managers at $87, 15% Lawyers at $88, and 10% Chief Executives at $126). Hourly rates for each occupational
group are the (rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment
and Wages, May 2024, published April 2, 2025, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are
defined using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.

13

Estimate of Cost to the Federal Reserve System
The estimated cost to the Federal Reserve System for collecting and processing this
information collection is $303,800.40

40

Total cost to the Board was estimated using the following formula: estimated FR 26 staff time of 1,000 hours
multiplied by $165,000 per year multiplied by a benefits factor of 1.25 divided by 2,080 hours per year plus an
estimated FR 29 staff time of 1,000 hours multiplied by $220,000 per year multiplied by a benefits factor of 1.25
divided by 2,080 hours plus estimated information technology costs of $72,500.

14