No doubt the Durbin Amendment will cut into debit card fee revenue for the big banks. But the new rule may end up a wash given the other fee raising activity underway.

"I had calculated that if the debit interchange law cut fees by 50 percent then it would require Bank of America to charge $4.50 per customer account," Susquehanna Financial Group David Hilder told TheStreet.com. "Since the law would cut 80 percent of fees, it is not surprising that Bank of America has come up with a price of a little over $6.00 a month for an account."

So, if the bank can raise via other fees $6.00 per account, then it's in pretty good shape.

Bank of America made news with its plan to roll out a pilot program in three states that will charge more fees, depending on how active an account is and how much they hold. It's fair to say aggregate fees will rise to at least offset the drop in revenue from the Durbin Amendment. Even for accounts that qualify for no-fee treatment, they may be induced to pay fees for other services. The bank will try to upsell them.

One issue is how aggressively banks will rely on these fees as a driver of revenue, which they sorely need. Yet, they cannot be seen as gouging in this climate.

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