under the second alternative an issuer bould comply with the standard as long as it does not receive an interchange fee above a cap, again, recommended to be 12 cents per transaction. for both alternatives the proposal defined the allowable costs to be the average value of authorizing clearing and settling transactions, varied with the number of transactions performed by the issuer over a calendar year. the average cost of clearance and settlement. the value of the caps in both alternatives and the safe harbor in the first alternative derived from information gathered through a survey of covered debit card issue herbs that the board conducted last fall. the board received numerous comments about all aspects of the proposed standards including the proposed definition of allowable costs and the two approaches. issuers and networks overwhelmingly supported expanded allowable costs to include a wider range of debit card costs beyond the costs of authorization and clearance and settleme settlement. among the costs to be included is fixed possessing costs, network fees and fraud losses, as