The comments are designed to help Treasury create a report on the future of money and payment systems that was requested in President Biden’s Digital Asset Executive Order on March 9, 2022. The comments reiterated Nacha’s position that digital assets might have a role in the improvement of the U.S. payments infrastructure over the long run, but that a more near-term improvement in the payments infrastructure could be achieved through the expansion of the operating hours of the Federal Reserve’s interbank settlement service. A digital asset such as a Central Bank Digital Currency (CBDC) could also provide an interbank settlement mechanism that could accelerate payments. Nacha has previously encouraged the Federal Reserve to introduce any CBDC initially as a form of central bank money solely for the purpose of settling interbank payments. Even if the Fed develops a CBDC and enables its use for the settlement of interbank payments, the Fed still should take much more immediate action to expand the operating hours of its existing interbank settlement service.

The letter followed up on discussions Nacha had with Treasury in June to correct a misstatement made by Secretary Yellen on the timeliness of payroll payments. A new payments infrastructure is not necessary to provide workers with access to funds on payday. A Direct Deposit to a bank account accomplishes this. The worker receives their pay at the start of each payday using a Direct Deposit.