Four financial services associations issued a letter to Congress on the eve of the one year anniversary discussing the contents of a new GAO study about the impact of Dodd-Frank.
The study shows that for smaller community banks and credit unions, which were supposed to be “exempted” from the fallout of this legislation, interchange revenue dropped by five percent in just the first three months of implementation, and that was before the network exclusivity and routing provisions took effect in April 2012. These provisions require financial institutions to enable their debit cards with two unaffiliated payment card networks which will likely cause even more substantial reductions in interchange fees to exempt issuers. The GAO further concludes that even more harm to community banks and credit unions is likely as the marketplace evolves.