PULSE recently released its 2011 Debit Issuer Study, which found that small debit card issuers on average expect a 73 percent decrease in debit interchange revenue as a result of pending interchange fee rules. While these issuers with less than $10 billion in assets are exempt from the regulations proposed by the Federal Reserve Board, they are critical of the interchange cap and skeptical that the exemption will be effective. The impact small issuers say they are expecting is greater than many anticipated. One exempt issuer in the 2011 Debit Issuer Study responded, “We see no impact in 2011, but over time (in 2012-2013), we expect interchange income will decrease due to marketplace pressures lowering the interchange rate.” Another exempt issuer commented that, “Even if a network were to offer a two-tier pricing schedule, the shift in market conditions would eventually require the interchange rate for exempt institutions to be reduced.”