Originally published in March 2024, this perspective discussed the CFPB late-fee rule. The CFPB records that the rule was vacated on April 15, 2025. It should not be treated as an operative merchant fee cap.
Separate the charge layers
A merchant’s charges can combine interchange, network fees and processor or acquirer charges. Review the signed pricing terms, transaction details and fee notices separately. An average processing percentage is not a substitute for the rates applicable to a particular transaction or contract.
The U.S. debit-routing distinction
The Federal Reserve’s October 3, 2022 clarification, effective July 1, 2023, required issuers to enable at least two unaffiliated networks for debit transactions, including card-not-present transactions. It did not change the interchange-fee requirements. This concerns debit routing, not a general credit-card price cap.
Ask the processor which eligible debit networks and transaction types are supported and how routing choices are made. Compare the complete cost, including switch or processor fees, against actual eligible volume. Do not infer a saving from a chart of industry averages or assume every transaction can follow the cheapest displayed route.
What to request
- Transaction-level debit and credit records, with the available card and channel information.
- Contracted interchange, network and processor pricing and relevant notices.
- The routing configuration and evidence of which eligible networks were used.
- A reconciliation of billed amounts against those records before discussing changes.
Any comparison should use the merchant’s actual eligible debit transactions and current provider terms, not a generic processing-cost percentage.