Letter to the Board on the Collection of Checks and Funds Transfers through the Fedwire

Re: Docket No. R-1891 and RIN 7100-AH23, Collection of Checks and Other Items by Federal Reserve Banks and Funds Transfers Through the Fedwire Funds Service and the FedNow® Service; Regulation J

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I. Introduction

The American Bankers Association (ABA) appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System's proposed amendments to Subpart C of Regulation J, codified at 12 C.F.R. Part 210, which governs funds transfers through the Fedwire® Funds Service (Fedwire) and the FedNow® Service (FedNow). The proposed rule, published in the Federal Register on April 10, 2026, would permit FedNow participants to use intermediaries—other than Federal Reserve Banks—to send funds transfers through FedNow. See Collection of Checks and Other Items by Federal Reserve Banks and Funds Transfers Through the Fedwire® Funds Service and the FedNow® Service.

Banks generally support responsible efforts by the Federal Reserve to enhance FedNow and to enhance its usefulness for the broader banking system. Banks see value in aligning parts of FedNow's legal framework with established Fedwire practices when it supports safety and soundness. At the same time, because FedNow operates as a real-time, continuously available, irrevocable settlement service, any expansion of permissible access models must be accompanied by clearly articulated regulatory safeguards.

II. Sanctions Screening Requirements

Banks agree that permitting the limited use of intermediaries may support certain additional use cases, including facilitating the domestic leg of a cross-border payment and enabling correspondent banking relationships to function more efficiently in a real-time environment. The Board's discussion in the preamble properly recognizes that Fedwire has long permitted intermediated payments under Regulation J without compromising settlement finality or the Reserve Banks' risk posture.

However, banks emphasize that FedNow differs materially from legacy payment systems in its continuous operation, immediate finality, and heightened fraud exposure.

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Letter to the Board on the Collection of Checks and Funds Transfers through the Fedwire

I. Introduction

II. Sanctions Screening Requirements

In Depth

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Letter to the Board on the Collection of Checks and Funds Transfers through the Fedwire

I. Introduction

II. Sanctions Screening Requirements

In Depth

Related Products

Our Experts

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