BANK LETTERHEAD
John Aafedt
Visa Global Op Regs Compliance
Dear John,
My bank has been a VISA member bank for the past ____ years. We appreciate that you have been in conversation with the Louisiana Bankers Association about VISA’s Operating Rules and how they relate to business in 2012. Our understanding is that the Operating Rules were written in 1972 at a time when credit cards were gaining acceptance and debit cards were not even thought of, much less being used for mass issuance by government entities and others. The current Operating Rules obligate VISA member banks to offer “free” cash advances to anyone who comes into our bank, whether customer or not, with a VISA debit card. We respectfully ask that you consider reviewing and updating the current Operating Rules for use in today’s environment.
Some of the issues we encounter under the current environment, especially with the mass issuance of debit cards that are costly to my bank:
o Daily cash disbursement limit of $5,000 is too high
§ Increased cash on hand, reducing amount of cash that could be invested
§ Increased cash going to non-customers, leaving none for customers
o Higher cash balances in ATMs and in branches
o Cost of more transactions, especially non-customer transactions with no ability to charge a fee
o Higher armored car expenses for increased shipments and/or extra shipments
o Employee time spent on non-customer transactions
o Compliance issues with attention to fraud
o Security issues with more cash in branches and more customers leaving branches with cash
o Monthly cost to be a merchant offering cash advances at every location
o Consider removing manual cash advance or if not, allow charge
o Reduce per transaction amount at ATM and in branch
We would be happy to provide more detailed information as needed for review. Please contact us. Thank you very much for your time and consideration. We look forward to hearing from you and would appreciate ongoing status updates.
Sincerely,
BANKER