PEP Episode 005 — The Durbin Amendment
- May 26, 2023
In this episode of the Expert Payment Podcast, James Huber and Jarvis Lagman go in for a deep dive into The Durban Amendment and what it means for the payments industry, especially now in 2023. What is the Durbin Amendment? Why does it exist? Who does it protect, and what should you know if you’re a merchant, agent, ISO or processor. See how you can assert your rights today. James and Jarvis explain it all in this episode.
Welcome to the Payments Experts Podcast, a podcast of global legal law firm ISOs, FinTech, pay fax agents, merchants, processors, acquiring banks and card brands. If these terms mean something to you, this podcast is for you. If these terms aren’t so familiar, this podcast is even more for you. We hope you enjoy this episode of pep, the Payments Experts podcast.
Welcome to this episode of the Payments Experts Podcast, a podcast of global legal law firm. Today we have managing partner of the law firm, James Huber, as well as Senior Associate Attorney Jarvis Lagman. The topic today, gentlemen, is the Durban Act. Jump right in.
Why are we talking about Durban today? Jarvis?
Jarvis Lagman (00:58):
So the Durban Act was passed after the 2008 financial crisis, part of the larger Dodd-Frank, um, uh, legislation, uh, legislative reform bill. And it’s really intended to protect consumers, right? So the reason for why the Durban Amendment is important in terms of the payments processing world is that it operates to perform two functions. It limits the amount of interchange fees payable to the, to the banks who issued credit cards to consumers. And it also imposes certain restrictions on the ability for, um, for processors and, and payment networks and their agents in, in the manner in which they’re able to process transactions, which we’ll go into in more detail later. But it’s really important in terms of protecting, uh, your rights as a merchant.
I think what’s interesting is that it’s really the only legislation that touches payments. Um, and, well, it’s probably the first, but, um, it also didn’t really work. The idea was, you know, the banks are killing people with these fees, but the banks retaliated, you know, I mean, you remember, you’re, remember your, your, you know, your savings account used to give you 3% Yeah. And your rewards cards from the bank. I had like, you know, US Bank, you know, good, good rewards card gone. Thanks a lot, <laugh>.
Jarvis Lagman (02:26):
Well, right, because at the end of the day, the banks are gonna offset any reductions in fees that they received through interchange by increasing fees or developing new products to generate revenue. Right. Ultimately, banks are, you know, profit making businesses that have shareholders and, you know, it’s, it’s their duty to their shareholders to, to figure out how to compensate for those fees. And, and I, and I think you make a good point about how this limited regulation didn’t necessarily attain the, uh, the objective it wanted to because it was so, it was very narrowly focused, right. For example, you know, the cap on interchange fees didn’t really address any of the other fees charged by the networks and the processors. Cause these are all deemed to be non interchange fees that aren’t subject to the cap. Right? Right. So part of the problem with, um, with the Durban Amendment ultimately, is that it only focused on the issuers and didn’t really see the full landscape of all the different actors who actually participate in the payments processing world.
Right. I mean, the, the one area that I think it was successful is it brought awareness, it brought awareness to the Hill about what’s going on with credit card processing. And I do know that Durbin is still a force. And when he, you know, so Covid, I’ll back up twice a year, visa and MasterCard raised interchange rates. Oh. Or they have changes, but since they’ve done it, it’s always been a raise. During COVID, they were getting ready to raise the rates. And I think Durbin looked at him, you know, ruffled his brows a little bit, and they didn’t do it because they’re going, whoa, whoa, whoa. We’re, you know, the world’s falling apart. You guys, you know, everything’s going electronic. You’re not cashing in an extra trillions <laugh>, you know, dollars. So it brought a, it, it brought awareness. I mean, that, that’s, you know, this is the only, the main thing, you know, that we talk about when we’re, you know, cuz people bring class actions to us all the time. And unfortunately most people have an arbitration clause, but Durban’s kind of the floor of where we’re going. This violates something. Cuz otherwise you’re just talking about Visa, MasterCard rules. Yeah.
Jarvis Lagman (04:38):
Because yeah. Cuz at the end of the day, and I think you make a good point about the actual market power that Visa MasterCard has over this entire industry, right? So, so to the extent that, you know, visa, MasterCard increases rates, it affects every, you know, roughly 70% of all transactions, right? Right. Only 70% of all transactions are done using a payment card. Right.
So a Visa or MasterCard.
Jarvis Lagman (05:04):
Yeah. So, so to the extent that any, any regulatory decisions that they make as a, essentially a quasi-private, a quasi regulator of this industry, you know, it’s gonna have this ripple effect throughout the whole, throughout the whole, um, you know, throughout, throughout the whole economy, frankly, just because, uh, you know, we’re living in an increasingly cashless digitized world, and whoever’s the gatekeeper of that world and who can make the rules has control of over not just, uh, you know, the the amount of fees paid by consumers, but merchants and all their, and all their different vendors and agents in the whole, in the whole industry. That’s kind of evolved around, you know, this, this specific, this specific niche, right?
Yeah. And it’s tough because Visa and MasterCard lobbying, I mean, you could probably look this up, but they’re, I know that their lobbying is insane. You know, we, we had a, a case where we thought we had, you know, a really good class action against visa slam dunk, and we went and you went and you looked at every single state they had lobbied for a carve out in this except for Michigan
Jarvis Lagman (06:17):
So they’re, they’re lobbying everywhere. Yeah.
Jarvis Lagman (06:22):
Um, I mean, and, and if you, if you think about, you know, how other, you know, cause, because arguably Visa MasterCard operate a utility, right? So, so to the extent that, uh, because everybody relies on these networks to run their transactions, uh, right there, there is a, there’s a case that the government does need to step in and put in more guardrails. And that, you know, kind getting back to the original point about Durban, that this is really a first step in, in, in a, in a longer journey to develop a more, uh, detailed regulatory framework governing how these transactions operate. And, and how, like for, for example, you know, uh, I have a background in securities. Um, so anybody who engages in, uh, purchaser sale securities needs to be a registered broker dealer. And Right. And part of being a registered broker dealer requires all sorts of, uh, background checks and due diligence requirements.
Jarvis Lagman (07:20):
And you need to have, you know, um, you know, an ethics background and, and you need to understand ethics rules. Um, and if you think about how some of the actors in our industry operate, you know, they operate in very, in, in a very similar fiduciary capacity, but without the guardrails requiring them to act in good faith without any of the fiduciary obligations that, you know, other similar brokers in, in other industries are governed by. All right. Cuz if you think about Fritz as an iso, you know, a, a merchant gets signed up by an iso, they’re, they’re putting a lot of faith in the ISO to be their representative to the processors and to the banks. And they rely on, on all of these agent, all these upstream agents to help guide them through a process. Cuz if you’re a merchant, you are, you’re an expert at running your business, you’re not necessarily an expert in how payments processing works and what fee sh you know, what, what fee structures are appropriate. And then all of a sudden now you’re relying on, on the guidance of, um, of experts that don’t necessarily have the same fiduciary obligations to them that maybe in other, in other industries they would.
Yeah. Well, who I, I like talking about Durban a lot. Um, I’m probably, we’re probably a small handful of people that actually like talking about it. And you know, the reason is when we came into this industry, we saw a bunch of really intelligent people. Um, we were working mostly with the salespeople, and they would start an organization and they would hire all of their childhood friends, their family, and pay them double what they would make anywhere else. You’d go to their office. It was very fun, very cool. But then I’d see these guys make mistakes. One, because they waited and they didn’t call me first <laugh>. Um, but two, because there’s not really any guardrails in this sp where you go, here’s what I can do and here’s what I can’t do. So, you know, the AGs for years were putting out different, you know, the way the AG works is somebody complains to them mm-hmm. <affirmative>, and you know, somebody has a cousin or who am ever there, and it gets to their table, and now you have an AG investigation and it’s expensive, you know, and, you know, there’s potential, you know, really bad fallout. But with Durban, we got a little bit of guidance, which was nice, but it’s guidance for who, who cares about Durbin?
Jarvis Lagman (09:53):
Well, the, the issuing banks, right? The issuers. Yeah. Um, and you know,
And why, why?
Jarvis Lagman (09:59):
Well be because Right. There’s a cap on their fees, and now they have to invent new fee structures to compensate
For the, to compensate for their difference. Right. Why else though? There’s more to it than just Well,
Jarvis Lagman (10:08):
Well, in terms of, you know, for instance, uh, we, you know, there, you know, there are two, you know, there are two main aspects to Durban, right? There’s the Kappa interchange fees, but then there’s also the limitation on the way transactions be run. Like specifically, uh, debit cards need to be, or, or, or terminals need to be enabled for at least two unaffiliated networks, right? And then there’s the prohibition on, on routing restrictions. Uh, and, and those are really important. But the, but for those rules to actually be effective, you need to actually understand how they work, right? So for example, the, uh, the prohibition on routing restrictions only applies if a merchant expresses a routing preference, right? So in the absence of a routing preference, like for, for example, you could, if you’re a merchant, you could go to your, you could go to your process processor and say, I want you to route me towards the cheapest network or the cheapest unaffiliated network. And by law, the proser will need to, AB would need to abide by that decision, or they will be in violation of Durban. How many merchants know about that? Right? So to the right, to the extent that a, these aren’t built into any merchant processing agreements where, you know, a merchant could, you know, basically argue for a provision in there that says, I want you to route me through the cheapest network. Uh, there there isn’t a lot of recourse because there isn’t a lot of awareness of the rule,
Right? And here’s how this is being misused. What we’re seeing is Fiserv, one of, I think probably the world’s biggest corporation buys up its own networks mm-hmm. <affirmative>, and they happen to be, I don’t know if they were before, but you know, now they’re the most expensive network. Mm-hmm. <affirmative> and Fiserv has the power to route their transactions to the most expensive network. And the merchants, you know, this is a bummer for our processor ISO clients, because they’re, they don’t get that revenue. Yeah. That’s not revenue to them, that’s expense. So they’re getting charged that their merchants are getting charged that now they have to lower their fees. I mean, we’ll see this with, you know, all sorts of IC down at the sales agents level. You know, here’s your fee share, here’s your buy rates. And then they go, oh, well, here’s this new compliance fee that you don’t charge in. And then the ISO has to, or the agent has to lower their share to keep the merchant happy. So we’re seeing that now, and this, like you said, it, it doesn’t violate Durban unless the merchants say something, but we are having success going, Hey, first data, or Fiserv, come on guys. And they, they are, you know, as happens most of the time when we send a, you know, scary letter, they say, okay, we’re sorry. We won’t do it again until next month. Yeah.
Jarvis Lagman (12:57):
Mean, maybe we’ll wait two months.
Jarvis Lagman (12:59):
And, and, and I think the hard part about this stuff, right? So, you know, the, the specific situation you described with Fiserv, if you think about timing, um, and I don’t want to be conspiracy theorists, but if you are gonna increase rates and route all your traffic through affiliated networks in November right. Before earnings <laugh>, right, right, right. I, I think that says something about your business practices and how you view your relationship with your customers. Yeah. Um, and, and our role here as a, you know, as a law firm, uh, is to protect your rights and to, you know, to call, call BS when you see
Bs. Yeah. Yeah. I mean, this one is complete home cooking. Yeah. It’s, so what we’re telling, you know, our clients to do is state the preference. And I asked you on the way in, is it enough to just say the cheapest one?
Jarvis Lagman (13:51):
Oh, yeah. I, because a, the, uh, the Durban amendment doesn’t specifically, right. Because a, you, I think the preference really is to protect the merchant. Right? So to the extent that the rule is actually designed to say that, you know, payment networks cannot inhibit a merchant’s routing decision. Right. The presumptions actually against the payment network to defend what it did. Right? Right. And so there’s a, so the reason for why the merchant has the duty to inform the processor, the, or the payment network of its preference is it’s, it’s because there’s actually just a very specific exception that in the absence or the, the language of the rule says in the absence of a routing preference, the, you know, essentially the payment network could, could resort to a default rule. Yeah. Right? So, so it really was supposed to fill in a gap where if the merchant didn’t express a preference, someone needs to make a decision. So we’ll allow the process to make a decision, but ultimately the whole point, the rule is to actually be very protective of the merchant. Right. So, so to the extent that the merchant expresses any preference, you know, it’s very likely that a court will look at the structure of the rule, the policy underlying the rule and say, listen, you said something. And now they have to abide by it. Cuz the whole point is to protect, protect the merchant, right? Who, who’s essentially the consumer in this transaction.
Yeah. Gentlemen, can I jump in here real quick? Do, yeah. Because on this point, is this for all merchants, is the message from the, from the rooftops, all merchants ought to now go ask for this. Or just if they’re with working with Fiserv,
Uh, everybody and well, Fiserv is the only one really cooking it, but everybody should do it. And really the processor should just do it for them. But I do wanna circle back on what you said of this Durbin was to protect the merchant. And we just went through, uh, what, two years of people realizing, oh my gosh, small businesses, they need help. Yeah. And so we’ve seen a, you know, a huge boost in cash, cash discounting and surcharging where you’re passing on the fees to the card holder and people all of a sudden going, okay, cool. I don’t want this guy going out of business. And I understand there’s a convenience to me just, you know, swiping my card. And Durbin too
Said, I mean, this was really aggressive. This was saying there has to be v there’s Visa, MasterCard, there needs to be somebody else too. Yeah. And that did, that didn’t pass. And I think we probably know wise because of lobbying. Um, but I think it was also confusing to people and they didn’t really get it. But the scary thing was, look what happened with Durbin one where I lost all my rewards cards. Yeah. And my saving account, there’s no even utility in having a savings account, particularly in this, this economy maybe. Um, but what would happen if you started cutting into Visa and MasterCard’s bottom line, what are they gonna do? Yeah. Am I gonna lose my airline rewards card now too? You can’t take that from me. Wait, wait. I can’t go sit in the back
Jarvis Lagman (17:00):
<laugh> Yeah. Of
The plane now.
Jarvis Lagman (17:02):
I know, right? It’s like, why’d we go to law school? We’re gonna sit in the back of the place.
Well, I might have to if I’m not using my rewards
Jarvis Lagman (17:07):
Points. I know. Jet Blue. Oh yeah, exactly. You’re gonna make me fly Southwest.
Yeah. We’ll be on spirit.
Jarvis Lagman (17:13):
Okay. Don’t go that far. Okay. Not <laugh>. Um, cause I’d rather flat my arms and then fly spirit. All right. Um,
That, that’s a different podcast episode. <laugh>
Jarvis Lagman (17:25):
<laugh>. Well, I think, I think, you know, part of even regulating Visa MasterCard right? Is this idea is that they’re actually a, the, the front man or the face for a conglomeration of banks, right? Right. So it’s, you know, so if you think about Visa MasterCards being less companies and more associations of banks, you know, it it, it puts the problem into different focus because A, each bank is different, right? So they’re, you know, if, even if you look at the text of Durban, it only applies to essentially to issuers of cards or banks that have a net worth greater than 10 billion, right? So you can imagine how, oh, all these like smaller regional banks who issue cards are not subject to that. And, and, and they even just have different incentives and different interests in terms of how and why and to whom they would issue cards and, and how they would manage their transaction flow.
Jarvis Lagman (18:19):
So I, I think it’s even hard, you know, as much as we talk about Visa, MasterCard and Visa MasterCard, you actually think about the brilliance of their, of their business model, right? It’s like, okay, you need to abide by these, these thousands of pages of rules that we promulgate, so you are allowed to put our mark on your cards. Right? Right. So really they’re, you know, going back to the point we’re talking about how these un MasterCard potentially we’re in violation of franchise rules, you know, subject to exclusions, you know, and we kind of, you know, we, we did some of the research and, and kind of found that even though they operated as a franchise, you know, they, they wouldn’t necessarily be, um, required to abide by those specific registration standards. But, but you know, the operation of the business is still the same.
Jarvis Lagman (19:00):
That ultimately it’s really a bunch of banks were issuing these cards who are doing it under the, under the trademark of either Visa, MasterCard and Visa. MasterCard really is just a face of an operation where all these banks are really operating in the shadows. Uh, and you know, in in, in terms of future re uh, legislation, you know, maybe, maybe what we really need to do is actually create more standardization on, on a regulatory level as, right. Like it shouldn’t be Visa, MasterCard creating those standards. It really should be either the federal government, you know, I would say the federal government just because interstate and we’d want standardization across the country.
So you’re pro C B D C then,
Jarvis Lagman (19:41):
The coin. The Fed. Oh, I mean, that wouldn’t be Visa. I mean, it’s still, they would, still would, would, cuz you’re probably loading up Yeah. From Visa and MasterCard, but that would take a lot, that could take a lot of away from Visa and MasterCard.
Jarvis Lagman (19:55):
Well, you know, like, I think for instance, if you think about what is, what actually is the, the success of the payment card, uh, network, um, business model, it really is the ability to dispute dispute transactions, right? So one of the problems with a crypto transaction is yes, this, the authorization settlement and clearing process is a lot quicker, but it also gives you a smaller window to get a charge back or dispute a transaction or really get your money in the event of fraud.
Except if it was cbd c they would know where it was and you can go get it. I mean, that’s actually one of the beauty of crypto crypto. I mean, Jeremy one time sent his money to the wrong, wrong place and he like went and found it on the internet or the blockchain hours later, it was wild hours later. Yeah. Went and found his money. So if there’s a central bank digital currency, the they’re gonna where it is all the
Jarvis Lagman (20:48):
Time. Well, well, I, I guess, you know, and, and this is kind of more of like a public enterprise versus a private enterprise, right? So like who does the investigation, right? You know, like in the case of a dispute, the
Big brother, they’re gonna know where you’re at all the
Jarvis Lagman (21:01):
Time, right? So, so the argument right, is okay, you know, the way the Csup operates now, visa, MasterCard, but also through the member banks, all of those parties are working in concert to inve to do an investigation of a dispute, right? Uh, so do you trust them or okay, let’s say this was a government managed payments network and there just, there’s a dispute. Would you want the government handling the dispute handling the investigation? Right? Uh, I, I mean, I think that’s a little outside the purview of specifically what we’re talking about just because it’s, it’s like, you know, I think each approach has pros and cons. Um, you know, but, but I think that’s actually really, you know, you know, we could have a frictionless payment, uh, system, but, but I think there’s some latency built in just to, in order to give people windows of time to correct pro, you know, correct problems like disputes and fraud and, and things like that, that if you didn’t have that window, people could just kind of take the money and run. Right? Right. And, and, and I think what you’re saying is okay with, uh, with, uh, um, with like a crypto coin or digital payment system operated by the government, there’s no place to run, right? Nowhere
To run. Um, they can be taking your parking tickets out, your child support. The scariest thing I heard somebody say is what if they put an expiration date on your money?
Jarvis Lagman (22:28):
Uh, better spend it. Yeah. Well, I mean. At the post office.
Jarvis Lagman (22:32):
So I, so I, you know, but I think that’s actually some of the, uh, you know, the, the, the drawbacks of having, you know, digital currency that we’re really getting away from this idea that people have vested property rights. Right? Right. And then it’s like, okay, so if we don’t have, right, like for instance, what, what is the beauty of paper Fiat money that, uh, absent it’s destruction, you have it, it has some, it’s, it’s a store of value in a way that can’t be manipulated, you know, it can’t remotely Oh,
Jarvis Lagman (23:07):
Remotely <laugh>, right? Sure. Right, because like, because for like, even just something like, okay, let’s say one day you add a digital wallet and you know, and, and all your money’s in it, and then we get hacked by foreign foreign power, or there’s an electricity outage or a power outage, and now you don’t have any money. Yeah. Right? Yeah. Um, right. So, so I think all of these ideas sound really good in a vacuum, but we, you know, we really discount the risk of market failure. And market failure happens all of the time
As we’re learning. Um, is, is Durbin, I mean, he’s got it out for Visa and MasterCard, clearly. Yeah. And we love him for it, um, because nobody else really is, you know, he’s got his, you know, team or whatever they call it when they start working together on the rare chan time that they do. Um, but is he looking at crypto too? I don’t think he is.
Jarvis Lagman (24:04):
I don’t think he is, but
Think he’s just on Visa, MasterCard, <laugh>.
Jarvis Lagman (24:06):
Yeah. Well, I mean, and, and I think like for instance, not to get into like a crypto discussion, right? I, I think for example, you know, we were looking, you know, we’re discussing the Ripple case and, and how much of whether or not, um, cryptocurrency is considered a security right under the Howi test, right? As an investment contract, you know, something like crypto, maybe you actually just amend the Securities Act and additive as a security, right? There’s actually a very quick fix, right? Like there’s, there’s billion, like there’s millions of dollars being spent on this litigation and people getting burned. And then all you actually need to do is add one word to the, to the securities act, and then it just forecloses these millions of dollars that are being spent, right? Yeah, I’m sure. Um, and, and, and it enhances investor protect, you know, so, so I, I think what’s actually really interesting about all the stuff, and maybe this, uh, the point of we’re talking about Durban is that what the beauty of regulation when done right, and, and done, not necessarily with the, the interests of lobbyists in mind and having a, you know, balanced different special interests, but really formulating a policy that works for everybody.
Jarvis Lagman (25:15):
I think that’s possible. I I think it’s difficult just given the climate. Yeah. But I think it’s possible because I think our technology, or, you know, like for instance, we were, I feel like at the office we’ve been really getting into, uh, discussion about chat G P T and, and you know, AI and, and how that’s gonna impact, um, you know, just life moving forward. And if you think about, okay, how can, how can these solutions be applied in a payments environment, right? So we could do those instant dis, you know, we could do instant fraud detection, right? Where every time’s running someone’s running a card, they’re scouring the internet trying to make sure that oh, they’re, you know, this person matches the card. Yeah. Right? Like, and, and we could do that in real time. So I think to the extent that we could kind of close that settlement window, yeah, a lot of it will actually be a product of our technologies, like as long, if we could get the same protections that we have now, but do it using techno technological interfaces that just enable to create more efficiency, I think.
Jarvis Lagman (26:16):
I think that’s, you know, and, and I think our regulatory framework needs to kind of be able to incorporate that, because I think that’s actually the hardest part about Durban is that it takes years to put these laws together and to lobby and get support, but technology doesn’t operate on, on a, on a horizon of years. It operates on a horizon of months, days, seconds, right? Every, every day someone’s coming out with a new, either a new variation of a technology, a patch, and there’s a chess match going on between people who are trying to crack the technology and people who are trying to fix it, and people who are trying to move it forward, right? And, and to have a regulatory scheme that’s able to incorporate all of that dynamism. I think that, you know, I think that’s the challenge.
It’s all order.
What I love about this podcast, gentlemen, is we go from the Durban amendment to crypto to government oversight and technology. It’s pretty amazing. Fantastic episode. Before we close it out, just in the closing moments here, um, I’m not sure if we touched on, uh, much the interchange cap in relation to the Durban. Do you guys wanna have some closing thoughts on that and take us out?
I I don’t know if it’s necessarily related.
Jarvis Lagman (27:25):
Um, well, it, I think it’s related in the sense that there is a very strong distinction between what are considered interchange fees and what are considered network fees, processing fees. Things are not governed by the interchange cap. Yeah. Right. So, um, you know, so what we’re actually talking about, you know, where some of the overages are in terms of, you know, of, of terms of rates getting raised on merchants and their direct agents, you know, you know, some of it’s interchange, but a lot of it’s also Fiserv and, and the network fees and, and their collusions, right? That are outside of the scope of Durban because Durban focused on the credit card brands and didn’t focus on some of these other vendors that, you know, that are not necessarily the face of the enterprise, but are just as integral, right?
And making a lot of money from it
Jarvis Lagman (28:20):
and making a lot of Right. I serve as a Fortune 500 company, right? Yep. Uh, and you know, and, and everything that they do impacts everybody in the same way that Visa MasterCard does, because right, like, if you’re gonna be charged 3%, 3.5, roughly 1.6, 1.6 of that goes, uh, to the interchange, but then the rest of that is carved up by the processors, the payment networks, the ISOs, right? So in that Scrum for that essentially 1.5 to 2%, you know, Fiserv at, at its affiliated networks are able to capture a greater and greater percentage just because of their market leverage. Yep. Right? And that’s outside of what interchanges.
James, I give you the last word today.
I, I’ve got nothing. That was a great conversation.
Excellent. Thank you guys for listening today to the Payments Experts podcast. Again, this was the managing partner of Global Legal Law firm, James Huber and Senior Associate Attorney Jarvis Lagman. Thank you gentlemen, and thank you for listening. All right. Thank you for listening to this episode of The Payments Experts podcast. New episodes first and third Thursdays. If you’re interested in learning more about PEP and how Global Legal Law Firm may be able to assist you, please visit us at global legal law firm.com. To schedule a free consultation, give us a call at (888) 846-8901 or email email@example.com. And once again, thank you for listening. 1, 2, 3.
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