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The Bottom Line

Federal regulators continue to advise on how banks and credit unions conduct due diligence for digital assets solution providers.

A lapse in vetting could expose FIs to an array of risks, ranging from reputational impact to non-compliance with government sanctions and BSA requirements.

Branch networks require significant investment, real estate is getting more expensive, and utilities and security costs are spiking. Offices can also be labour-intensive, assuming financial institutions can attract and retain the right frontline staff.

At the same time, branch traffic is declining, limiting opportunities for locations to generate revenue. If ROI is a primary consideration, it’s getting harder for banks and credit unions to justify having large branch networks.

It has been almost a year and a half since the Fed had requested public comment on a “non-substantive” proposed amendment to Regulation II that would 1.) specify that the prohibition on network exclusivity applies to card-not-present debit card transactions, 2.) clarify the responsibility of the issuer to enable at least two unaffiliated networks to comply with the prohibition on network exclusivity, and 3.) standardize and explain the use of certain terminology. The proposal was anything but non-substantive and would have fundamentally altered issuers’ compliance obligations under Durbin. The Fed received more than 2,750 comments, and it has taken nearly a year since the comment period was completed to receive a final ruling. The ruling has finally arrived.