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#2091454 - 08/03/16 08:23 PM Reguation II - Debit Card Interchange Fees
hawksfan Offline
100 Club
Joined: Mar 2004
Posts: 114
Iowa/Illinois
Hi,

We are examined by the Federal Reserve Bank. They are asking us the following question
Has an independent review (external directors’ examination or via an internal audit function) of Regulation II been completed and did it indicate compliance?

We have not performed an audit but I don't see that an audit is required per the regulation. Has anyone else been asked this by their examiner?

Does anyone have an audit program covering Regulation II that they would be willing to share?

Thanks!

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Audit
#2092096 - 08/08/16 01:48 PM Re: Reguation II - Debit Card Interchange Fees hawksfan
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
I almost responded on Friday that I wonder what would happen if you said "no." But I thought I would do a little digging on this over the weekend and see if anyone had insight. And then we got the same question this morning!

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#2092101 - 08/08/16 01:54 PM Re: Reguation II - Debit Card Interchange Fees hawksfan
Christy Goza Offline
100 Club
Joined: Jun 2010
Posts: 118
Cleveland, TN
_________________________
Christy Griffith

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#2092109 - 08/08/16 02:10 PM Re: Reguation II - Debit Card Interchange Fees Christy Goza
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
They are wanting to know if we checked to make sure our cards are enabled for processing over two networks. (Seems like that was YEARS ago.) But they also want to know if we have been checking activity to show that transactions are being routed over two networks.

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#2092287 - 08/09/16 02:05 PM Re: Reguation II - Debit Card Interchange Fees hawksfan
Tabbetha, CRCM Offline
Junior Member
Joined: Feb 2009
Posts: 44
Mississippi
We recently had a Compliance Exam with the FDIC and state examiners. They looked at our cards (which are VISA debit cards) for at least 2 networks and they did verify transactions from pulse and switch. Maybe this is a new hot topic.

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#2092295 - 08/09/16 02:16 PM Re: Reguation II - Debit Card Interchange Fees Tabbetha, CRCM
Cornfed Turtle Offline
Diamond Poster
Joined: Mar 2006
Posts: 1,323
"...Somewhere in Middle Americ...
How did you check your transactions?

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#2099201 - 09/19/16 07:06 PM Re: Reguation II - Debit Card Interchange Fees hawksfan
DEL Offline
Platinum Poster
Joined: Oct 2002
Posts: 730
Maine
Bump - I also would like to know how you checked your transaction for at least two networks.

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