August 02, 2021

Nacha Files Comment Letter on Federal Reserve Policy on Payment System Risk

Urges Fed to Expand Services for Interbank Settlement for all Payment Systems

Nacha filed comments on Aug. 2, 2021, with Board of Governors of the Federal Reserve System on the Fed’s proposal, “Potential Modifications to the Federal Reserve Policy on Payment System Risk to Expand Access to Collateralized Intraday Credit, Clarify Access to Uncollateralized Credit, and Support the Deployment of the FedNow Service.”

As the Fed expands and enhances its services to support FedNow, its own instant payment system, Nacha strongly encourages the Fed to make those services available concurrently and on the same basis to all payment systems, including the ACH Network. Competition among payment systems should be based on the quality, characteristics and benefits of the payment systems themselves, rather than on their differential access to Federal Reserve-provided utilities.

Nacha strongly encourages the Fed to:

  1. Renew its commitment to the strategy in the January 2015 Strategies for Improving the U.S. Payment System Report that included a plan to enhance the National Settlement Service to “make it more attractive as a settlement vehicle for private-sector arrangements” with the exploration of 24x7 operating hours;” and
  2. To follow through on its previously stated intention to propose an additional extension of operating hours for NSS and Fedwire.


Download Comment Letter