FRB published a "Compliance Guide to Small Entities" on debit interchange. See http://www.federalreserve.gov/bankinforeg/regiicg.htm#f1

Learned something new from the guide that I hadn't heard before: "In order to assist small issuers in identifying which networks have implemented two-tier fee structures, the Board will publish annually a list of the average interchange fee each network provides to its covered issuers and exempt issuers."

How about making it a rule that all networks process transactions in real time only. No delays. Put them all on a level playing field.

RE: ODPs: Hows about we return all NSF checks, debits, etc. Then the consumer can cry about the "fee" the merhcant charges or that he can no longer write a check nor will his debit card be accepted by the merchant. Think about the impact on commerce, merchant losses, etc.

Oops! My bad. Was I ranting, again. Must be the water, or the regulations!!!