Mobile wallets, often funded by linked bank accounts, are sometimes described as decoupled debit accounts in disguise — and may suffer from the same challenges decoupled debit faced.

Overall, decoupled debit is alive and well at companies such as National Payment Card and First Data, and is a fixture of many gas station loyalty programs. But the model's most prominent failure, Tempo Payments, links its demise explicitly to the Durbin amendment's slicing of debit interchange fees.

Under the hood, many mobile wallets and decoupled debit cards draw funds from a linked bank account through the automated clearing house network. Both products also promise merchants will either save money on transactions or recoup their expenses through increased payment volume.

However, "some programs that are widely accepted could be hindered by the uncertainty of Durbin," says industry analyst Todd Ablowitz, president of Centennial, Colo.-based Double Diamond Group, LLC.

The uncertainty stems from a court ruling that invalidated the Federal Reserve Board's cap on debit interchange fees, declaring the Fed's cap to be too high. A judge asked the Fed to set a new cap.

"If debit [interchange] gets inexpensive as a result of Durbin 2.0, why would a merchant go through the trouble of enrolling customers in an ACH product?" Ablowitz says.

The pricing issue is what sunk Tempo Payments, formerly Debitman, two years ago. The company said the Durbin amendment made its business model unsustainable, because it relied on a certain level of debit interchange.

But the unpredictable regulatory landscape does not hide the fact that a merchant can develop a large following by making meaningful offers to customers who use decoupled debit and mobile accounts.

Peter Guidi, vice president of sales for National Payment Card, a Coconut Creek, Fla.-based decoupled debit program provider, says ACH payments represent the key step for merchants getting into mobile because of lower costs.

"Mobile payments are here today through these programs," Guidi told merchants at the Ramp conference last month in Chicago. "Your customers are mobile, so are you?" he asks.

The return on investment with ACH is that credit card transactions through a mobile wallet would generate higher rates as card-not-present fees, Guidi says.

National Payment Card provides mobile technology called MPay that merchants can brand for their own services.

PayPal has had great success with online payments through ACH enrollment, while Starbucks hit the mobile jackpot with a prepaid option, as both systems charge low interchange for the merchant, Ablowitz says.

"Lots of companies are exploring decoupled debit, ACH and prepaid," says Ablowitz. "But we haven't seen one completely take off yet on a wide scale, but that is part and parcel with mobile payments right now."

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