Q: The final rule becomes effective on October 1, 2011. How should an issuer allocate payments and incentives for purposes of determining whether the issuer received net compensation in calendar year 2011?
A: The prohibition on net compensation applies only to those payments and incentives received, and fees paid, on or after October 1, 2011. If an issuer receives an incentive payment in December 2011 for that issuer's debit card-related activities during all of calendar 2011, the issuer may choose a reasonable method for allocating the incentive payment between the first 9 months of 2011 and the last 3 months of 2011. (Added September 14, 2011)
This Q&A was obtained from FRB’s website, in a section for Regulation II (Debit Card Interchange Fees and Routing) Frequently Asked Questions, which may be found here: