An Access Regime for the Visa Debit System: A Consultation Document – July 2005 3. Options

The Bank has considered two broad options.

The first option is to request that Visa review and modify its rules and the second is to impose an Access Regime on the Visa Debit system, mirroring that imposed on the Visa credit card system.

This first option has the advantage that it may avoid the need for further regulation. The main disadvantage is that it could take an extended period of time and would have an uncertain outcome. Given Visa's decision-making structure, any rewriting of its rules would be likely to involve not just its Australian operations but also its Asia-Pacific and International boards.

In the Bank's opinion the second option is more likely to promote competition in card acquiring, and to do so in a timely fashion. While the Bank prefers to avoid regulation where possible, it is of the view that the public interest would be best served by timely resolution of this issue. If SCCIs are able to acquire Visa credit card transactions, but not Visa Debit transactions, they are likely to find it difficult to compete with other institutions in the business of credit card acquiring. Without an access regime, SCCIs may be denied membership of Visa.