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GAO to Congress on Interchange Fee Regulation: Yellow Light
by David S. Evans
Last week the General Accountability Office (GAO) released it much awaited report on interchange fees. Congress had asked the GAO, the respected investigative arm of Congress, to wade into this battle between merchants and cards systems earlier this year when it passed the CARD Act. There's something for everyone in this report which is why both merchant and cardholder advocates are claiming that it backs their positions. Here's what GAO finds:
- Consumers who use credit cards have benefited from competition in credit cards with lower fees and more rewards although consumers who don't use credit cards may face higher prices because merchants pass along the cost of acceptance.
- Merchants are paying more for interchange fees because consumers are using cards more and because MasterCard and Visa have raised some rates.
- Merchants receive benefits from accepting credit cards but at least some merchants claim that the costs outweigh the benefits.
- Reducing interchange fees to merchants could result in consumers paying higher fees and getting less rewards but consumers might also benefit from lower prices.
The GAO's bottom line is: "Although various options to lower interchange fees exist, impacts on cardholders could be mixed and each option has implementation challenges."
Although both sides can point to sound bites from the report that back their positions I think a fair reading of the GAO's conclusion is that it presents a "yellow light" to Congress (It is more or less consistent with the warning that I gave Congress in my recent testimony). Even though it sometimes couches the findings in tentative prose the GAO seems to agree that reducing interchange fees will result in people paying more to use credit cards, having less availability of credit, and having reduced rewards. It cites the experience in Australia where there is really no controversy over the fact that fees went up and rewards went down as a result of the halving of interchange fees there. It recognizes that there's a flip side to this. Merchants will pay less for taking cards and might pass on some of those savings to consumers. One can debate the extent to which this will happen and how long it will take but there's widespread agreement that since we're talking about small saving per transaction that it is almost impossible to measure and verify these benefits.
The GAO Report does not present any findings that would support the regulatory interventions being advocated by merchants and that are covered to various degrees by some of the bills winding their way through Congress. There is nothing that suggests that consumers overall will benefit from interchange fee caps. In the best of worlds reducing interchange fees will take money out of one pocket (from the higher cost to consumers for cards) and put it in another pocket (the lower cost at check out). The GAO Report mentions benefiting consumers that don't use cards but there aren't many such people and they don't spend much. There is also nothing in the report that concludes that society would be better off if merchants could steer consumers to cash and checks. It seems counterintuitive that we'd be better off continuing to use paper-based payment methods that originated centuries ago rather than electronic methods.
If I were a member of Congress I'd also be pretty concerned about the GAO's conclusions from a purely political perspective. Consumers will not perceive Congress as having done them any favors if measures to reduce interchange fees are passed. They will pay higher fees for cards and they will have their rewards slashed. They won't notice any savings at checkout even if there are some. We already saw this movie in Australia.
Bio: David Evans
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Comments
Comments
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It's pretty easy to be sanguine about the GAO report and blase about the issues surrounding interchange fees when the authors of the report, and most of the merchant advocates, fundamentally miss the key economic questions. Sure, there could be issues about merchants "paying too much" - whatever that means - and cash users getting screwed - a darn shame for the poor unbanked folks - but a rebuttal of those positions doesn't require much thought. For example, to deal with the unbanked poor, the obvious solution would be to get them cards so that they could partake in the largesse (sic?) of the interchange system. Perhaps not credit cards, if we're feeling paternalistic, but at least get them bank accounts and debit cards. In other words, it's not the interchange arrangement that screws them, rather they're just poor. And it sucks to be poor. Why screw with the payment system to alleviate poverty?
Hence, we have David's review of the GAO report which concurs with the GAO that it's a difficult issue without really emphasizing why.
The key issue, of course, is the efficiency of payment patterns. David notes this issue, but really focuses on the transfers inherent to the system and the difficulties involved in evaluating those transfers. This naturally follows from the GAO's focus on the transfer aspect of the issue. What the GAO completely misses, and what David naturally downplays, is the issue of whether interchange fees or, more generally, unbalanced user fees in a setting with market power distort payment patterns so that some payment methods are overused or underused at the expense of others.
When they're at their best (which isn't often), the merchant advocates make arguments that note potential distortions in payment patterns. In particular, they note the sig v. PIN discrepancy in which sig has higher interchange fees which encourages higher sig use (through sig rewards) despite its arguable technological inferiority to PIN (e.g. fraud prevention). The obvious response: it's not that sig interchange is too high, rather PIN interchange is too low. If we want to increase PIN use at the expense of sig, jack up the PIN interchange so that we all get better terms for our PIN transactions. O/w, a decrease in sig interchange may induce a substitution towards cash or check. God forbid.
At the end of the day, David is arguing against a position that is ignorant of the core economic issues surrounding interchange. Or, more likely, David's opposition isn't ignorant of those issues, rather it intentionally ignores them. Because, fundamentally, those issues are difficult to answer - what is the (socially) efficient way to perform a transaction?
So, in the end, David's response to the GAO report is correct - this is a difficult issue. But not because of anything that the GAO said. Or anything that David emphasized in his review.Posted by Chabot, 04/12/2009 2:11am (9 months ago)
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The merchant community strategy to lower card acceptance costs focuses on litigation and legislation. The GAO report is a “best case” result for those fighting the battle, namely the lawyers and politicians, providing just enough hope to assure the continued stream of revenue funding this cause. Merchants may be better served if they focused their efforts on the changing the consumers method of payment. Other forms of payment that create disintermediation are available, and associations of retailers could develop methods of payment that would exhibit platform effects. It is unlikely that the banking or payment card industry would wage a fight with retailers over competitive programs regardless of any violation of the operating rules, particularly in this political environment. What may be closer to true is that this type of effort would be expensive, and therefore run the risk of exposing the value of the current system.
Posted by Peter Guidi, 25/11/2009 3:31pm (9 months ago)
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