Federal rules on credit card practices instituted a year ago kicked off a year in which fee income, a large and dependable source of retail banking profits, came under assault on many fronts. Lawmakers and regulators instituted a series of policies that restricted the industry's ability to charge for everything from credit card overlimit transactions to checking account overdrafts.
And the threat to consumer fees is far from over. Lawmakers are considering bills that would further restrict overdraft fees and regulate credit card issuers' interchange fees. They also have begun making noise about automated teller machine fees.
Whatever the outcome of such continuing government scrutiny, the banking industry has been shaken out of its complacent reliance on consumer fee income.
"I don't think we have one [bank] customer that's not concerned about the possibility of all these things happening, including interchange," said Brian Shniderman, a director of the banking team at Deloitte Consulting LLP. "Many didn't anticipate that some of the things that have already happened would happen and would happen so quickly. Now I think there's this [mentality of] 'anything can happen and we need to be prepared for everything,' " including the possibility of ATM fee regulation and interchange caps.
Although the industry has long faced the threat of interchange regulation, the debate intensified over the summer, as merchants capitalized on consumer rage over late fees and other cardholder charges. 7-Eleven Inc. channeled that anger into a petition to "stop unfair credit card fees," which received more than 1.66 million customer signatures.
During his confirmation hearing early this month, in response to concerns raised by Sen. Charles Schumer, D-N.Y., Federal Reserve Chairman Ben Bernanke said his agency "would definitely take a look at ATM fees."
By all accounts, the largest — and most damaging — blow has already landed, with the Fed's new rule that, as of July 1, banks must get customers' permission before enrolling them in overdraft protection programs.
According to the consulting firm Novantas LLC, the banking industry reaped $36 billion, or more than half of its revenues on checking accounts, from overdraft fees last year. By contrast, net interest margin accounted for only $13.2 billion, or 19%, of checking account revenues — slightly more than the amount generated by interchange fees on debit cards. Novantas forecast similar figures for this year. But in the coming years it projected that as much as $17.5 billion of checking account revenues could evaporate as a result of the Fed's required opt-in provision. In a "worst-case" scenario where lawmakers pass bills that would further restrict overdraft protection fees, Novantas estimated that industry revenues from checking accounts could fall by more than 40% over the next two years, to $38.6 billion in 2011.
"At some banks, as much as 40% to 50% of those fees are in jeopardy," said Rick Spitler, a managing director at Novantas. "What are you going to do, close a bunch of branches? That's scary — but they have to take huge amounts of costs out."
Aside from cost-cutting measures, banks may eventually have to rely more on net interest income to expand the top and bottom lines.
"If fees are limited, the only other sources of revenues are lower deposit rates or higher loan rates. There's no place else to go," Spitler said. "You're making the banks' revenues even more dependent on credit as a result."
Some observers would welcome such a shift. "Overdraft fees for bankers are like heroin — they know it's bad for them (particularly in building the trust relationship with customers that they want), but the revenue just feels so good," Carol Coye Benson, a managing partner in the consulting firm Glenbrook Partners LLC, wrote in a November blog post. "The Fed's new rules are detox."
