[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-1-en-105":3,"doc-seo-279445-105":53,"doc-detail-279445-en":127},{"code":4,"msg":5,"data":6},0,"success",[7,14,19,24,29,34,39,44,49],{"id":8,"doc_module":9,"doc_module_name":10,"category_name":11,"show_sort_weight":12,"slug":13},11,1,"Template","Presentations",90,"presentations",{"id":15,"doc_module":9,"doc_module_name":10,"category_name":16,"show_sort_weight":17,"slug":18},12,"Resumes",80,"resumes",{"id":20,"doc_module":9,"doc_module_name":10,"category_name":21,"show_sort_weight":22,"slug":23},14,"Invoices",70,"invoices",{"id":25,"doc_module":9,"doc_module_name":10,"category_name":26,"show_sort_weight":27,"slug":28},15,"Posters",60,"posters",{"id":30,"doc_module":9,"doc_module_name":10,"category_name":31,"show_sort_weight":32,"slug":33},16,"Social Media",50,"social-media",{"id":35,"doc_module":9,"doc_module_name":10,"category_name":36,"show_sort_weight":37,"slug":38},17,"Forms",40,"forms",{"id":40,"doc_module":9,"doc_module_name":10,"category_name":41,"show_sort_weight":42,"slug":43},18,"Letters",30,"letters",{"id":45,"doc_module":9,"doc_module_name":10,"category_name":46,"show_sort_weight":47,"slug":48},21,"Paper Templates",5,"papers-templates",{"id":50,"doc_module":9,"doc_module_name":10,"category_name":51,"show_sort_weight":4,"slug":52},158,"General","general-158",{"code":4,"msg":54,"data":55},"ok",{"site_id":56,"language":57,"slug":58,"title":59,"keywords":60,"description":61,"schema_data":62,"social_meta":120,"head_meta":122,"extra_data":124,"updated_unix":126},105,"en","amazoncom-letter-re-rulemaking-pursuant-to-efta-section-920","Amazon.com Letter - Re: Rulemaking Pursuant to EFTA Section 920","","Amazon.com, Inc. submits comments supporting rulemaking under Section 920 of the Electronic Fund Transfer Act (EFTA). The letter argues that debit card interchange must be “reasonable and proportional” to issuers’ costs by eliminating interchange pricing discrimination between card-present and card-not-present transactions. It advocates interchange at par, limits interchange fees to actual authorizing, clearing, and settling costs, and allows fraud prevention adjustments only after effective fraud reduction steps with issuer-absorbed chargeback risks and required cost 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standard does the letter say the Federal Reserve Board must enforce under EFTA Section 920?","Question",{"text":109,"@type":110},"It states that interchange received or charged by regulated debit issuers must be “reasonable and proportional” to the costs the Board may consider under the Act.","Answer",{"name":112,"@type":107,"acceptedAnswer":113},"How should interchange pricing differ between card-present and card-not-present debit transactions?",{"text":114,"@type":110},"The letter argues the distinction must be eliminated and interchange for electronic debit transactions should be set at par, or otherwise limited strictly to actual costs.",{"name":116,"@type":107,"acceptedAnswer":117},"When should fraud prevention adjustments be allowed, according to the letter?",{"text":118,"@type":110},"Adjustments should be allowed only when the issuer has taken “effective steps” to reduce fraud and the issuer bears the chargeback risks, with fraud adjustments reduced by required deductions for merchant fraud prevention, PCIDSS, and chargeback costs.","https://schema.org",{"og:url":78,"og:type":121,"og:title":59,"og:site_name":91,"og:description":61},"article",{"robots":123,"canonical":78},"index,follow",{"doc_id":125,"site_id":56},279445,1790286836,{"code":4,"msg":5,"data":128},{"doc_id":125,"user_id":129,"nickname":88,"user_avatar":130,"doc_module":9,"category_id":40,"category_name":41,"doc_title":59,"doc_description":61,"doc_content":131,"file_id":132,"file_url":133,"file_type":134,"file_size":135,"view_count":101,"is_deleted":4,"is_public":9,"is_downloadable":9,"audit_status":9,"page_count":20,"language":136,"language_code":57,"site_id":56,"html_lang":57,"table_of_contents":137,"faqs":138,"seo_title":139,"seo_description":61,"update_tm":140,"read_time":47},4398048949847,"https://ap-avatar.wpscdn.com/avatar/400002536579ef2da7f?_k=1778318612642679267","amazoN.Com  \nNovember 20,2010  \nBy Electronic Delivery  \nMs.Louise L.Roseman  \nDirector,Division of Reserve Bank Operations and Payment SystemsBoard of Governors of the Federal Reserve System20th Street &Constitution Ave.,NWWashington,DC 20551  \nRe:Rulemaking Pursuant to EFTA Section 920  \nDear Ms.Roseman:  \nOn behalf of Amazon.com,Inc.(“Amazon”),I respectfully write to provide informationto assist the Board of Governors of the Federal Reserve System (the “Board”)in its rulemakingpursuant to Section 920 of the Electronic Fund Transfer Act(“EFTA”or the“Act”).This sectionof the Act requires the Board to set standards to ensure that any interchange received or chargedby regulated debit issuers is \"reasonable and proportional\"to costs.As described and supportedin this letter,the current interchange pricing discrimination between so-called “card-present”and“card-not-present”debit card transactions must be eliminated under the Act.  \nMore specifically,Amazon believes that interchange is only“reasonable”if issuerswould not issue debit cards at all without it.Because issuers would continue to issue debit cardseven without interchange,interchange should be set at par.This result should apply to all debittransactions irrespective of the merchant or merchant category in which the transaction takesplace.The elimination of discriminatory treatment would also apply if the Board permits issuersto recover their incremental costs of authorizing,clearing and settling debit transactions.Thosecosts do not vary much,if at all,based on the merchant category in which the transaction isconsummated,and the argument that the costs are greater for card-not-present transactions doesnot withstand serious scrutiny.As a result,rules faithful to the Act must eliminate the card-present/card-not-present distinction for debit transactions because it cannot be justified as  \nNON-CONFIDENTIAL VERSION  \nreasonable or proportional to the cost incurred by issuers with respect to card-not-presenttransactions.Our specific conclusions are as follows:  \n·The interchange pricing distinction between card-present and card-not-present debittransactions must be eliminated because it is neither \"reasonable”nor“proportional\"tothe issuers'costs that the Board may consider under the Act.We agree with othercommentators that electronic debit transactions be interchanged at par.  \n● If the Board determines that issuers should receive some interchange fee for electronicdebit transactions,the amount of that interchange must be limited to the actual andnominal costs of authorizing,clearing and settling debit transactions.Because the costsof performing these services do not vary materially across merchants,the resulting ratesmust be applied equally to all transactions,regardless of the location of the merchant'sstorefront,in order to be “reasonable”and “proportional”as required by the statute.  \n● The Board should set standards that allow an adjustment for fraud prevention as\"reasonably necessary”only when the issuer has taken “effective steps\"to reduce fraud,and the issuer absorbs all or virtually all chargeback risks for fraud.Moreover,thestandards should be performance-based and technologically neutral since there arenumerous ways fraud can be reduced with respect to card-not-present transactions and themarket should make those decisions.  \n● Lastly,consistent with the statute,no issuer may receive a fraud adjustment under the Actuntil a merchant's fraud prevention,Payment Card Industry Data Security Standard(PCIDSS)and chargeback costs have been deducted from any fraud adjustment claimed by anissuer.In other words,if issuers bore the entire cost of preventing fraud,it would beappropriate to adjust for fraud prevention.If,however,a merchant bears both the risk offraud and the cost of fraud prevention(as is currently the case),allowing issuers a fraudadjustment is neither fair nor rational.  \nHistorically,the Payment Industry Has Used.Arbitrary Merchant Categories to JustifyInterchan","cbCaiaScAqESH8h3","https://ap.wps.com/l/cbCaiaScAqESH8h3","pdf",668719,"English","# Comments on EFTA Section 920 Rulemaking\n## Eliminate card-present/card-not-present debit interchange discrimination\n## Set interchange limited to actual incremental processing costs\n## Fraud prevention adjustments: effective steps and cost deductions\n## Background: merchant categories and historical interchange justification","[{\"question\":\"What standard does the letter say the Federal Reserve Board must enforce under EFTA Section 920?\",\"answer\":\"It states that interchange received or charged by regulated debit issuers must be “reasonable and proportional” to the costs the Board may consider under the Act.\"},{\"question\":\"How should interchange pricing differ between card-present and card-not-present debit transactions?\",\"answer\":\"The letter argues the distinction must be eliminated and interchange for electronic debit transactions should be set at par, or otherwise limited strictly to actual costs.\"},{\"question\":\"When should fraud prevention adjustments be allowed, according to the letter?\",\"answer\":\"Adjustments should be allowed only when the issuer has taken “effective steps” to reduce fraud and the issuer bears the chargeback risks, with fraud adjustments reduced by required deductions for merchant fraud prevention, PCIDSS, and chargeback costs.\"}]","Amazon.com Letter - Re: Rulemaking Pursuant to EFTA Section 920 | PDF",1789520823]