approach, we recommend that the final rule adopt a modified version of the proposed rule, that is, apliblgible to all covered issuers. under the final rule, the maximum permissible interchange fee would be the sum of a base component. we recommend that the base component set at 21 cents, which corresponds to the 80th percentile issuers average transaction allowable costs as reported in the board survey of covered issuers. we further recommend that the component set at five basis points of the transaction value, ri flekting the median issuer's fraud losses as reported in the same sur vafr. each covered issuer permitted to receive an interchange fee that did not exceed the sum of two components without demonstrating the actual per transaction allowable costs. with respect to the statute's requirement that an interchange fee be reasonable and to portional to the cost of the issuer, we believe that the cap delineates a separation of a fee that's reasonable and not reasonable. moreover, because it's based on certain costs for affecting particular electronic debit transactions, the standard ensures

approach, we recommend that the final rule adopt a modified version of the proposed rule, that is, apliblgiblehe maximum permissible interchange fee would be the sum of a base component. we recommend that the base component set at 21 cents, which corresponds to the 80th percentile issuers average transaction allowable costs as reported in the board survey of covered issuers. we further recommend that the component set at five basis points of the transaction value, ri flekting the median issuer's fraud losses as reported in the same sur vafr. each covered issuer permitted to receive an interchange fee that did not exceed the sum of two components without demonstrating the actual per transaction allowable costs. with respect to the statute's requirement that an interchange fee be reasonable and to portional to the cost of the issuer, we believe that the cap delineates a separation of a fee that's reasonable and not reasonable. moreover, because it's based on certain costs for affecting particular electronic debit transactions, the standard ensures that sfees are proportional to those costs as re