Coming up is an important date, April 1, 2012, for the Federal Reserve’s interchange rule . On that day, the network exclusivity provisions go into effect for issuers. The interchange rule requires debit card issuers to ensure debit cards may be processed on at least two unaffiliated networks. For example, a credit union could comply by permitting personal identification number (PIN) transactions to be processed on one network and signature transactions to be processed on another, unaffiliated network. Issuers are – of course – free to enable more than two networks if they choose. Debit card issuers must be in compliance with this rule by April 1, 2012. This requirement leads to two other questions. Would it be permissible to comply with this requirement by using regional networks? What should an issuer do if the two unaffiliated networks that it uses merge? The Federal Reserve answered those questions in § 235.7(a)(2)-(4) . Regional Networks. Sections (a...
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