TouchNet LIVE! Confidential
COHEAO Annual Conference 2012
Durbin Debit Dynamics
John McElroy, Business Development TouchNet
Wall Street Reform and Consumer Protection Act of 2010
[ Dodd-Frank Act]
• 533 new regulations • 60 studies Senator Richard Durbin (D-IL) • 94 reports The “Durbin Amendment”
Where the Money Goes
Sources: GAO (analysis); Art Explosion (images).
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Discount vs. Interchange
Issuer’s Cost Your Bank & Processor
87% Card Issuing BkBank 44%*
Visa and Mastercard REWARDS
National Retailers Association estimates it cost the average American Family $427 per/year in higher retail prices
* http://www.bos.frb.org/economic/ppdp/2010/ppdp1003.pdf
Durbin’s Primary Issues
High Fees (1.4%) Rewards (44%) Inflated Retail Prices Monopolies forming
Senator Richard Durbin (D-IL)
What Monopoly?
Debit = PIN Debit Credit = Signature Debit Issuers “Banks”
Interlink & Maestro NO CAP $$$ • Rewards! • Lower Fees • No PIN Required • Less Risk w/PIN • No Added Txn Fee • Fewer Chargebacks $.50 • Zero Liability CAP 1.4% Merchants Consumer “Schools” s “Students ”
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Who’s Regulated and Who’s Not?
Fed Regulated
DEBIT INTERCHANGE
Durbin Amendment Key Components (for Merchants)
1. FRB to regulate debit interchange 2. Issuers must provide access to 2 unaffiliated debit networks 3. Merchants have the right to route transactions 4. Discount for “cash-like” payments 5. Min / Max for credit cards
1. Debit Card Interchange Regulation
21 cents for allowable costs 1 cent for fraud prevention 5 basis points ad valorem 5 cents per $100
Effective October 1, 2011
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Interchange Examples
$1,000 Tuition Transaction Before After Interchange for card issuer (1.2%) $12.00 $ .72 Card processor fees (20 bps) $2. 00 $2. 00 Total discount fees $14.00 $2.72
2. Merchant Routing Rights
Merchants have the right to route transactions to the network of least cost Taking the routing issue out of the hands of consumers
Merchant X
Interlink & Maestro X
3. Minimum of Two Unaffiliated Networks All cards issued, from this point forward, must have two unaffiliated networks Provides choice and ppprevents monopolies
Front Back
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4. Discount for Cash Allows merchants to discount for cash-like payments
Cash-like payments may ildinclude: Signature and PIN Debit ACH Checks Cash Student ID Cards
5. Min/Max for Credit Cards
Credit Card – Minimum $10.00 (set by FRB) Credit Card – Maximum Government Higher Education?
Just take the Banana!
Exceptions : Cards issued by exempt banks
Less than $10 billion in assets Over 15,000 banks and credit unions exempt touchnet.com/durbin
Refund Cards?
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Government-Administered Prepaid and Debit Cards Direct Express U.S. Debit Cards Navy/Marine Cash Cards
Bottom line - Covered vs. Exempt
About 40% of debit cards are exempt, but that number is growing What does this mean…
Visa Credit vs. Debit Trends
25.0%
20.0%
15.0%
10.0%
5.0% Credit Debit 0.0% 1Q2007 3Q2007 1Q2008 3Q2008 1Q2009 3Q2009 1Q2010 3Q2010 1Q2011 3Q2011
-5.0%
-10.0%
-15.0%
-20.0%
Source: Visa's quarterly reports on their US-only payment volume (dollars, not transactions).
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Unintended Consequences
For Consumers Free checking will be harder to find Debit rewards will diminish Possible debit transaction fees
Unintended Consequences
For Merchants New monthly account fees Limited debit processing options Merchant Service Providers Micropayments (vending machines) Higher credit card interchange Increased credit card usage
Credit Cards on Campus
Half of undergraduates have 4 or more credit cards Twenty-one percent of college students have between $3000 and $7000 in credit card debt Half of seniors graduate with debt of over $4100 Only 17% of students pay off the entire credit card balances each month
Source: Sallie Mae 2008 Study
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What are students buying with Credit?
Source: Sallie Mae 2008 Study
The Convenience Fee Strategy
A fee applied to a payment method to help offset the cost of processing 25% of schools using a convenience fee 99% of these merchant accepp,t MasterCard, Discover, and Amex only.
Payment Mix and Convenience Fees
15%
15% Credit ACH
Debit 85%
85% Before After
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Convenience Fee Compliance
Flat Fee XX XX Tiered (Scale) XXX Percentage X X X Required for all XX* Pmt Types Permitted in 3rd XXX Party Services Allows In-line X* X Payments
* MasterCard current program is making an exception for this. Certain restrictions apply.
To Fee or Not to Fee?
To Fee (the good) Not to Fee (the ugly) Save BIG money Credit is growing Save students from Credit interchange is credit woes riiising
To Fee (the bad) No Visa Backlash Challenge for Internationals
Case Study: 6-Year Review
Total Trans. Total Dollars % of % of Avg. Dollar Pmts Dollars Per/Trans. CC 36,290 $51,553,766.41 16% 9% $1,420.61 ACH 194,364 $513,968,684.63 84% 91% $2,617.71 $565,522,451.04
$565,522,451.04 X 2.2% (85% of total pmts) = $10,575,269
$1,762,544.83 cost savings per year
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6-Year Case Study – Payment Trend
$120,000,000.00
$100,000,000.00 2004
$80,000,000.00 2005 2006 $60,000 ,000 .00 2007
$40,000,000.00 2008 2009 $20,000,000.00 2010
$0.00 ACH CC
The Visa Factor
100’s of schools have eliminated VISA credit “Non-event” But now you can bring VISA back, for Debit…
What about International Students?
Options for International Students
Alternative Channel (i.e. phone) UnionPay (largest credit card in the worlrd) and JCB Wire Transfers
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States with “Surcharge” Statutes
State Statute California CA CIVIL § 1748.1 Colorado CO ST § 5-2-212 Connecticut CT ST § 42-133ff Florida FL ST § 501.0117 Kansas KS ST § 16a-2-403 Maine ME ST T 9-A § 8-303 Massachusetts MA ST 140D § 28A New York NY GEN BUS § 518 Oklahoma OK ST T 14A § 2-417 and OK ST T 14A § 2-211 Texas TX FIN § 339.001
Are Convenience Fees Right for Your Campus?
Payment Strategy for Merchants
Contact Your Merchant Service Provider Unbundle debit from credit in agreements Ask for “Cost Plus” pricing Keep low $$$ payments in mind Leverage Campus Cards
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Debit Strategy for Payment Apps
Contact Campus Commerce Provider Make sure you can take advantage of intelligent routing at the payment application level RtRoute to ACH Route to Campus Cards Route to PIN/PINless Debit
Durbin Debit Summary
Push PIN and PINless, as the exempt numbers continue to grow Plan for an increase in credit card usage Re-consider using a Convenience Fees Strategy as a deterrent to Credit, thus boosting ACH and Debit
Thank You!
TouchNet John McElroy [email protected] 913.599.6699
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