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Financial Services Law Insights and Observations

Federal Reserve Banks Seek Public Input on Threats to Payment System

Payment Systems Federal Reserve Mobile Payment Systems

Fintech

On September 10, the Federal Reserve Banks issued a public consultation paper  that identifies “key gaps and opportunities” in the U.S. payment system. They include: (i) payment recipients prefer other forms of payments than checks but exercise little control over the sender to request a preferred form of payment, (ii) the system lacks a “near-real-time” payment capability, (iii) innovations have not gained significant market penetration while legacy systems tend to be more ubiquitous, (iv) legacy systems lack certain desired features, including, for example, assurance that a payment will not be returned or reversed, (v) cross-border payments are slow and costly, and lack fee and timing transparency, (vi) some digital wallet applications reduce the visibility and choice of payment instrument at the point of sale, (vii) businesses’ legacy payment and accounting systems make straight-through processing difficult, but are costly to change, and (viii) data security fears inhibit adoption of electronic payments. The paper outlines certain desired outcomes and seeks input on strategies and tactics to address the perceived gaps and shape the future of the domestic payment system. Interested stakeholders can submit comments until December 13, 2013.