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As discussed in a previous blog, the Federal Reserve began seeking comments on proposed changes to Reg II of the Durbin Amendment in May. At that time, the Fed said that it felt the changes would be non-substantial and would not include more compliance obligations. Currently, the Fed bars issuers from restricting the number of unaffiliated networks for debit card transactions to fewer than two, including one signature network and one PIN network. The new proposal would make issuers responsible for ensuring that all transactions with US merchants can be routed across two unaffiliated networks.

While the Fed characterized this change as a simple clarification, it is anything but, as evidenced by the over 2,600 comments received. It is clear this issue is complex, substantial, and would increase compliance obligations.

We have sorted through the comments posted on the Fed's website and various government sites to summarize the key points for both sides of this argument.

In late July, the National Credit Union Administration (NCUA) issued a request for comment on the current uses of digital assets and their potential impact on the financial system. The NCUA plans to use this input to help shape its role in safeguarding consumers and the system as these emerging technologies evolve.

The request largely mirrors previous outreach by bank regulators, although the NCUA expanded its scope to include the rapidly growing field of decentralized finance (DeFi). Unfortunately, the credit union response has been muted, so the NCUA extended its deadline for comments to October 27. SRM encourages credit unions to make their voices heard on this strategically important issue.

SRM responded to the NCUA, which you can read here. Our NCUA letter serves as a solid primer on the cryptocurrency topic and includes several examples of existing banking initiatives, the highlights of which we’ll summarize below.

Budgeting and planning season is usually a routine time for evaluating your business priorities and associated costs. However, while some banks and credit unions have already set their 2022 budgets, others are still calculating forecasts or waiting for more data.

Too often, management teams and boards plug vendor costs into their annual budgets and forecasts without questioning whether those contracts can be improved. This is undoubtedly a more complex task than ever as we face the coming winter months and the uncertainties surrounding the lingering impact of COVID-19.

There is, however, one area that is a sure opportunity for cost savings in your budgeting cycle – vendor contracts.

Banks and credit unions tend to plug vendor costs into their budgets and forecasts without questioning whether those contracts can be improved. This is often a mistake.

The truth is, no matter what the economic conditions, it is possible to reduce vendor costs without switching vendors or impacting service levels.

Here are 5 questions to ask when it comes to vendor contracts during this critical budget season:

As discussed in a recent blog post, banks and credit unions of all sizes continue to navigate a bizarre disconnect. Awash in a steady stream of deposit inflows from both businesses and consumers, institutions are hard-pressed to generate sufficient loan demand to put these funds to profitable use.

A crucial part of the challenge stems from account acquisition capabilities not keeping pace with customers’ digital evolution. This trend was already well underway but accelerated during the pandemic. SRM’s recent white paper, How Financial Institutions Can Boost Account Growth to Move with Changing Margins, outlines an actionable methodology for leveraging data analysis and market expertise to identify and act on a consistent stream of opportunities.

Here’s a preview of some of the insights covered in the white paper.

In response to the banking industry’s recent influx of deposits, several recent bank acquisitions show how some banks are responding to the pressure of putting liquidity to work.

Midsize banks like Truist Financial, Fifth Third Bancorp, Regions Financial, and some community banks have announced acquisitions where they plan to hold onto loans that the sellers would typically roll off the balance sheet.

Their objective? To redeploy billions of dollars in deposits held by the acquirers, shore up net interest margins, and boost returns.

Rumor is that a further tightening of the Durbin Amendment is on the near-term horizon for card issuers. The most concrete evidence is the Fed’s May request-for-comment on regulations for debit routing of online transactions.

The Fed wants to clarify the regulatory requirement that at least two unaffiliated payment card networks must be enabled for all debit card transactions, including card-not-present (CNP), and card-issuing banks and credit unions will be held responsible. Some terminology will also see standardization.

While the Fed positioned its query as a “non-substantive clarification,” many of the 453 comments submitted so far express a belief that the proposal, if enacted, would have a significant impact on issuers. Meanwhile, bankers are entering a period of uncertainty as they closely monitor the situation for implications to P&L.

If there were any lingering doubts about the potential impact of the buy now, pay later (BNPL) installment credit model on card economics, Square’s recently announced $29 billion acquisition of Afterpay likely put them to rest. Nonetheless, we see Apple’s plan to enter the fray with a feature built into Apple Pay as the more significant near-term concern.

Though much is still unknown, the unofficially dubbed “Apple Pay Later” could potentially be more threatening to card issuers than existing BNPL products. It could also further complicate the Apple - bank/credit union/debit issuers relationship, which could already be described as “frenemies” at best.

It’s an inconvenient truth - the timing of customers’ financial needs don’t always align with balance sheet strategy or marketing campaigns. Due to the pandemic, banks and credit unions were flooded with an unprecedented level of deposits but faced muted demand for the loans that put these funds to work.

Although no one has a silver bullet to synchronize customer needs with portfolio strategy, there may be an equation. SRM’s latest white paper, How Financial Institutions Can Boost Account Growth to Move with Changing Margins, offers a disciplined approach to being present when customers are “in-market” as well as a “growth equation” to boost account growth performance.

In recent years, challenger banks, neobanks, and other fintech startups have intensified their efforts to compete as financial services providers. Now, regulators have renewed interest in shifting the odds in their favor.

By obtaining a new specialized charter through the Office of the Comptroller of the Currency (OCC), new competitors may gain strategic advantages over more conventional banks and credit unions.

Here is a closer look at some legal and regulatory developments which could determine just how entrenched fintechs will become in the payments system – and how competitive they can be with core banking products and services.

SRM recently released its list of 2021 midyear trends that banks and credit unions should monitor during the second half of this year. Naturally, these developments didn’t appear out of thin air – our top-performing project managers and experts make it their business to examine and spotlight those topics which carry the greatest strategic impact for payments and financial services.

In this post, SRM shines a light on some big acts we’ve long anticipated will draw attention by the millions, billions, and trillions.