The following guest post is an excerpt of a white paper by Ivy Sprague, product development architect for The Members Group (TMG).
At first glance, newly regulated credit and debit programs can seem a bit like the weather – out of your control and all over the radar (of legislators). But what leadership of community-based financial institutions (FIs) must realize is that like the weather, card programs can be managed.
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If you enjoy spending your time driving around and taking pictures of ATMs, have I got just the friends for you! Meet Nancy Kinder and Ray Harrison, a Michigan couple who are notorious for trekking across the state of Michigan and finding ATMs that lack the proper fee-signage required by Regulation E. It would be laughable if the results of the couple’s hobby weren’t class action lawsuits – which have been filed on their behalf against 36 credit unions and banks in the past two years. The couple is keeping busy as they have recently filed four more lawsuits based on this issue.
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As I am sure you are all undoubtedly aware, the Federal Reserve’s upcoming rule on interchange will have profound impacts on the credit union industry. While, financial institutions under $10 billion are legally exempt from the reasonable fee provisions of the rule they will not be exempt from the financial impacts. Additionally, all financial institutions regardless of size are subject to the routing restriction provisions contained within the rule. Needless to say, exempt or not this rule has the potential to have a profoundly negative impact on the credit union industry. However, there may be some hope on the horizon, but it will require your help.
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It’s that time of year again when college basketball teams take to the hardwood to determine who will reign as king of the basketball court. This time is affectionately referred to as ‘March Madness’. While not constrained just to the month of March, one could certainly call the garnishment process ‘madness’.
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Last week I was fortunate enough to listen to a wonderful presentation on social media and technology by Mr. Robert Rutkowski. During the presentation, Mr. Rutkowski stressed the importance of social media in the world today, for both personal and business purposes. I have to admit, I agree with Mr. Rutkowski – however I didn’t realize just how much until I recently lost access to my Facebook account. It has been almost two weeks now and I feel incredibly disconnected from the world without access to Facebook. While this may seem a little silly to some, I can assure you that there is nothing silly about the benefit credit unions can receive by effectively using social media tools.
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I know it can sometimes seem that as soon as you have complied with a new regulation you turn around and there is yet a newer regulation that must be implemented. It feels like it is a never ending wave of regulation, continually crashing against the shores of the credit union. Well today I have a bit of good news.
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Is there anything more entertaining than some good debit interchange debate? Not for me there isn’t. But I happen to be a lawyer, so I love to argue – I mean debate…Anyway, the recently proposed rule from the Fed regarding debit interchange fees has certainly sparked a great deal of discourse and debate. And for good reason as it seems the rule has come with more questions than answers.
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