CRE sent out a letter a couple of months ago on this issue. We had an action item concerning it, in fact. Here's my post on that from July:
The Center for Regulatory Effectiveness sent a letter to several government officials concerning UIGEA regulatory burdens. It's at
http://www.thecre.com/pdf/McInerney_Letter.pdf. The points brought up in the analysis may be good for us to use in our letters and in our comments on the proposed regulations (once they are released, starting the comment period.
Some points:
There is strong evidence that a substantial number of credit card issuers are small businesses.
Census Bureau data strongly suggests that a substantial number small companies are in engaged in financial transaction processing services.
Small, innovative American technology companies will be directly and/or indirectly impacted by the rule.
The rule will place significant direct and indirect burdens on a substantial number of small entities, potentially altering the competitive situation in financial transactions industries and leading to further consolidations in already highly concentrated industries.
The letter also contains a number of people to whom we may consider writing, including:
Ms. Roberta K. McInerney
Assistant General Counsel for Banking and Finance
Room 2304
Department of the Treasury
1500 Pennsylvania Avenue, NW.
Washington, DC 20220
The Honorable Robert J. Portman, Director, The Office of Management and Budget
The Honorable Thomas M. Sullivan, Chief Counsel for Advocacy, U.S. Small Business Administration
Mr. Scott G. Alvarez, General Counsel, The Board of Governors of the Federal Reserve System
Mr. Peter A. Bieger, Deputy Assistant General Counsel, Banking and Finance
Dennis W. Carlton, Ph.D., Deputy Assistant Attorney General for Economic Analysis