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New Financial Reform Law----Effective Dates
July 21, 2010
Later today, President Obama will sign into law the Wall Street Reform and Consumer Protection Act. Here are the effective dates of the three provisions of significant interest to the industry:
Effective Tomorrow
· Merchants will be able to set minimum amounts for credit card usage as long as the minimum does not exceed $10 per transaction (i.e. you no longer have to accept credit cards for purchases under $10 but you cannot set higher minimum payment levels such as $15 or $25) and you cannot differentiate between bank issuers or card networks (i.e. you cannot set a $10 minimum for use of a Visa card but not for a Discover card).
· Merchants will be able to offer customers discounts for payment made with cash, checks, debit cards, or credit cards, as long as the discount is offered to all customers and is clearly disclosed to the extent required by federal and applicable state law. In the case of discounts for debit or credit card payments, you cannot differentitate between bank issuers or card networks.
Effective July 2011
· The Federal Reserve has until April 2011 to issue regulations to ensure that interchange fees on debit card transactions are "reasonable and proportionable" to the cost incurred by the card issuer with respect to the transaction. The regulations will become effective in July 2011. NRA, working within the Merchants Payment Coalition, will provide guidance to the Federal Reserve to ensure the best possible outcome for the regulations, which will significantly reduce interchange fees on debit card transactions.
Effective Tomorrow
· Merchants will be able to set minimum amounts for credit card usage as long as the minimum does not exceed $10 per transaction (i.e. you no longer have to accept credit cards for purchases under $10 but you cannot set higher minimum payment levels such as $15 or $25) and you cannot differentiate between bank issuers or card networks (i.e. you cannot set a $10 minimum for use of a Visa card but not for a Discover card).
· Merchants will be able to offer customers discounts for payment made with cash, checks, debit cards, or credit cards, as long as the discount is offered to all customers and is clearly disclosed to the extent required by federal and applicable state law. In the case of discounts for debit or credit card payments, you cannot differentitate between bank issuers or card networks.
Effective July 2011
· The Federal Reserve has until April 2011 to issue regulations to ensure that interchange fees on debit card transactions are "reasonable and proportionable" to the cost incurred by the card issuer with respect to the transaction. The regulations will become effective in July 2011. NRA, working within the Merchants Payment Coalition, will provide guidance to the Federal Reserve to ensure the best possible outcome for the regulations, which will significantly reduce interchange fees on debit card transactions.
