FR3064_20230120_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, with
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 Board modified the instructions for the FR 3064b to clarify responses for debit card
transactions when multiple networks are involved in the processing of the transactions. The
Board also modified the instructions for the FR 3064a and FR 3064b to include guidance that the
Board has previously provided in response to questions from respondents.
The current estimated total annual burden for the FR 3064 is 85,445 hours, and would
remain unchanged with the revisions.
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
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.
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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
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.
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.
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. In general, the Debit Card Issuer Survey collects
information on two types of debit card programs and transactions: dual-message and singlemessage.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
5

See 15 U.S.C. § 1693o-2(a)(3)(B).
See 76 FR 43394, 43436 (July 20, 2011).
7
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.
6

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prepaid cards.
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 the same set of questions asked in Section II, above, for general-use prepaid card
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; chargebacks to and returns from acquirers; 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.
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

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Revisions to the FR 3064
Debit Card Issuer Survey (FR 3064a)
The Board adopted the following changes in the Debit Card Issuer Survey instructions to
include guidance that the Board has previously provided in response to questions from
respondents:
• Added “Credit-push transactions (other than, where appropriate, returns), sometimes
referred to as original credit transactions (OCTs)” to the General Instructions, Section II
(All Debit Card Transactions), “Do Not Include” list to indicate that credit-push
transactions should not be included in the response.
• Modified the General Instructions, Frequently Asked Questions, Q9.A to read: “A debit
card transaction is the use of a debit card (including a general-use prepaid card) by a
person as a form of payment in the United States to initiate a debit to an account. Such
transactions include those conducted with both business and consumer debit cards. Debit
card transactions include charitable contributions, payments made to satisfy an obligation
(e.g., tax liability), or payments made for other purposes, such as to fund another account
(sometimes referred to as account funding transactions (AFTs)). Debit card transactions
do not include credit card transactions, transactions initiated at an ATM, or credit-push
transactions, sometimes referred to as original credit transactions (OCTs).”
The Board will implement the revisions starting from the next iteration of the Debit Card
Issuer Survey.
Payment Card Network Survey (FR 3064b)
The Board modified the instructions for the Payment Card Network Survey to clarify
guidance for survey respondents. The revisions provide instructions for reporting when multiple
networks are involved in the processing of transactions. The Board also modified the instructions
for the Payment Card Network Survey to include guidance that the Board has previously
provided in response to questions from respondents. The Board will implement the revisions
starting from the next iteration of the Payment Card Network Survey.
Through recent communications with survey respondents, the Board has become aware
that for debit card transactions where multiple networks are involved in the processing of the
transactions, the involved payment card networks may be interpreting the existing survey
instructions differently from one another. Such differing interpretations could potentially lead to
overcounting of transactions, if all involved networks report such transactions in their survey
responses, or undercounting, if none of them do. 12 The changes to the survey instructions
12

To illustrate, consider an example of two networks, A a nd B, that enter a reciprocal arrangement in which
Network B provides services that allow Network A’s debit cards (i.e., debit cards that have been issued by
depository institutions under agreement with Network A) to be used at a merchant that accepts Network B but does
not directly accept Network A. Network B may perform some or all of the processing functions for transactions
performed with Network A’s debit cards at such a merchant. For its part, Network A may perform certain processing
functions for such transactions, particularly with respect to issuers of Network A’s debit cards. Network A may also
establish fees for issuers, including network fees and the interchange fees that issuers pay and receive, respectively.

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outlined below clarify which network should report such transactions, looking to ensure
consistent reporting across respondents and eliminate the possibility of under- or overcounting of
transactions in the survey responses.
The Board clarified the survey instructions to specify that a network should report values
associated with debit card transactions for which that network establishes the interchange fee
received by issuers, even if that network outsources some or all processing functions to another
payment card network. Conversely, a network should not report values associated with debit card
transactions for which another network establishes the interchange fee received by issuers, even
if the former network performs some or all processing functions for these transactions on behalf
of the other payment card network. The clarification would be implemented through the
following changes:
• Modified the text under General Instructions, Section II (Debit Card Transactions) to
read: “Please enter totals for transactions related to debit cards, including general-use
prepaid cards, linked to U.S.-domiciled accounts involving a merchant located in the
United States during the calendar year (CY) 20XX. Important: In some cases,
transactions may be processed by multiple networks due to the outsourcing of some or all
processing functions. Please note the special instructions below to ensure proper
treatment of such transactions.”
• Removed “All debit card transactions (including general-use prepaid card transactions).”
from General Instructions, Section II (Debit Card Transactions), “Include” list.
• Added “Transactions for which your network establishes the interchange fee received by
issuers, even if your network outsources some or all processing functions for these
transactions to one or more payment card networks.” to General Instructions, Section II
(Debit Card Transactions), “Include” list.
• Modified the General Instructions, Section II (Debit Card Transactions), “Do Not
Include” list to indicate that none of the following should be included in the response:
(a) “Credit card transactions,” (b) “Transactions initiated at an ATM,” (c) “Credit-push
transactions (other than, where appropriate, returns), sometimes referred to as original
credit transactions (OCTs),” and (d) “Transactions for which another network establishes
the interchange fee received by issuers, even if your network performs some or all
processing functions for these transactions on behalf of the other payment card network.”
To ensure that the revised survey instructions clearly and adequately clarify responses for
debit card transactions when multiple networks are involved in the processing of the transactions,
the following questions are included in the Federal Register notice:
• Are the proposed revisions to the survey instructions clear on which network would be
responsible for reporting transactions when multiple payment card networks are involved
in the processing of the transactions?
• Are there potential challenges to reporting transactions based on the revised instructions?
If so, are there further changes that the Board should consider to alleviate such
challenges?

In this situation, the current survey instructions do not specify whether Network A, Network B, or both should report
transactions when both networks are involved in the processing of the transactions.

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•

Are there other situations, similar to those described but involving different facts and
circumstances, for which reporting would not be clarified by the proposed revisions? If
so, are there further changes that the Board should consider to provide clarity in these
situations?

In addition, the Board further clarified the survey instructions by including guidance that
the Board has previously provided in response to questions from respondents and removing
glossary items no longer relevant to the survey:
• Modified the General Instructions, Glossary of Terms, “Debit card transaction” definition
to read: “Debit card transaction: Use of a debit card (including a general-use prepaid
card) by a person as a form of payment in the United States to initiate a debit to an
account. It does not include transactions initiated at an ATM, including cash withdrawals
and balance transfers initiated at an ATM. For more details, see General Instructions,
Frequently Asked Questions, Q8,” to (a) harmonize definitions across FR 3064a and
FR 3064b and (b) align the definition to the language in 12 CFR 235.2(h).
• Modified the General Instructions, Frequently Asked Questions, Q8.A to read: “A debit
card transaction is the use of a debit card (including a general-use prepaid card) by a
person as a form of payment in the United States to initiate a debit to an account. Such
transactions include those conducted with both business and consumer debit cards. Debit
card transactions include charitable contributions, payments made to satisfy an obligation
(e.g., tax liability), or payments made for other purposes, such as to fund an other account
(sometimes referred to as account funding transactions (AFTs)). Debit card transactions
do not include credit card transactions, transactions initiated at an ATM, or credit-push
transactions, sometimes referred to as original credit transactions (OCTs).”
• Removed General Instructions, Glossary of Terms, “Number of merchant
establishments” definition because the Payment Card Network Survey no longer collects
such information.
Time Schedule for Information Collection
The Board plans to make the Debit Card Issuer Survey and Payment Card Network
Survey available online in the first quarter of every survey year. 13 Institutions typically have 90
days to respond to the survey. Institutions are also expected to provide clarifications, corrections,
and adjustments as requested to complete their submission.
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 is targeting a publication of the Payment Card Network Survey results
and the Debit Card Issuer Survey results by, respectively, the end of the third and fou rth quarter
of every survey year.
13

See https://www.federalreserve.gov/paymentsystems/regii-data-collections.htm to access prior versions of the
surveys.

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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,14 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.15 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 issu ers, 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.
Public Comments
On July 13, 2022, the Board published an initial notice in the Federal Register (87 FR
41718) requesting public comment for 60 days on the extension, with revision, of the FR 3064.
The comment period for this notice expired on September 12, 2022. The Board did not receive
any comments. The Board adopted the extension, with revision, of the FR 3064 as originally
proposed. On November 29, 2022, the Board published a final notice in the Federal Register (87
FR 73301).
Estimate of Respondent Burden
As shown in the table below, the estimated total annual burden for the FR 3064 is 85,445
hours, and would remain unchanged with the revisions. The Board estimates that there are 527
chartered institutions that, together with affiliates, have assets of $10 billion or more and that

14

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

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may issue debit cards. 16 In addition, the Board estimates that there are 15 payment card networks
that process electronic debit transactions.17 These reporting requirements represent
approximately 1.2 percent of the Board’s total paperwork burden.
Estimated
number of
respondents18
527
15

FR 3064
FR 3064a
FR 3064b

Estimated
annual
frequency
1
1

Total

Estimated
Estimated
average hours annual burden
per response
hours
160
84,320
75
1,125
85,445

The estimated total annual cost to the public for the FR 3064 is $5,165,150.19
Sensitive Questions
These collections of information contain no questions of a sensitive nature, as defined by
OMB guidelines.
Estimate of Cost to the Federal Reserve System
The estimated cost to the Board for collecting and processing these information
collections is $172,500.20

16

See https://www.federalreserve.gov/paymentsystems/regii-interchange-fee-standards.htm for a list of institutions
that are known to be non-exempt.
17
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 2020.
18
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), https://www.sba.gov/document/support-table-size-standards.
19
Total cost to the public was estimated using the following formula: percent of staff time, multiplied by annual
burden hours, multiplied by hourly rates (30% Office & Administrative Support at $21, 45% Financial Managers at
$74, 15% Lawyers at $71, and 10% Chief Executives at $102). Hourly rates for each occupational group are the
(rounded) mean hourly wages from the Bureau of Labor Statistics (BLS), Occupational Employment and Wages,
May 2021, published March 31, 2022, https://www.bls.gov/news.release/ocwage.t01.htm. Occupations are defined
using the BLS Standard Occupational Classification System, https://www.bls.gov/soc/.
20
Total cost to the Board was estimated using the following formula: estimated staff time of 2,000 hours multiplied
by average hourly rate of $50, plus estimated information technology costs of $72,500.

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