The Fed needs your input

The Federal Reserve System Board of Governors is seeking public input on potential actions the Federal Reserve could take to promote ubiquitous, safe and efficient faster payments in the US through real-time interbank settlement of faster payments.

After extensive analysis of the current faster payment solution for big bank exchange, BBOK believes it is likely not the right answer for banks under $10 billion in assets. Companies are rushing to develop pieces of a solution, but the pieces are not fitting together to form a cohesive network. We are hearing from the industry that vendors continue to push them to make fast decisions by using fear of being left behind as a scare tactic. Do not be pressured by those tactics.

Bankers’ Bank of Kansas is committed to finding a solution that best benefits Kansas community banks. We are actively working with a coalition of bankers’ bank operations staff to identify the best community bank solution, and make it available as soon as a comprehensive plan is created.

One of the pieces we believe is of utmost importance is the role of the Federal Reserve to settle faster payment funds. A fundamental role the Fed plays is ensuring a safe, robust US payment system regardless of delivery method. While the Board of Governors is not committing to any specific actions, potential actions include the Federal Reserve developing a service for 24x7x365 real-time interbank settlement of faster payments; and a liquidity management tool that would enable transfers between Federal Reserve accounts on a 24x7x365 basis to support services for real-time interbank settlement of faster payments. The Board of Governors is seeking input on whether these actions, separately or in combination, or alternative approaches, would help achieve ubiquitous, nationwide access to safe and efficient faster payments. It is BBOK’s position that the Fed’s involvement in this manner would level the playing field for institutions of all sizes.

You can read the entire Request for Comment here. We urge you to educate yourself and submit your comments to the Fed. If you want to discuss strategies, need assistance drafting your position, or would like more information, please contact Chris Gilbert at 800.999.5725.


How to Submit Your Comments

All community banks are encouraged to submit their comments for the Board of Governors’ review and consideration by December 14, 2018. Public comments will be posted as submitted on the Board of Governors website. You can access the link at If you wish to remain anonymous, do not include your information in your comments. 


You may submit comments, identified by Docket No. OP – 1625, by any of the following methods:

• Agency Website: 

• E-mail: Include Docket No. OP – 1625 in the subject line of the message.

• FAX: (202) 452-3819 or (202) 452-3102.

• Mail: Ann Misback, Secretary, Board of Governors of the Federal Reserve System, 20th Street and Constitution Avenue, N.W., Washington, DC 20551.

 The Kansas Correspondent - 3rd Quarter 2018