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Cathy E. Minehan, President and Chief Executive Officer,
Federal Reserve Bank of Boston
BAI Transaction Processing Conference
March 26, 1998
Good
morning. It's a pleasure to be with you here in New
Orleans at this comprehensive and exciting conference.
Just looking at the program serves as a reminder of
how fast the pace of change is now in a wide range of
technologies and financial service products. And it
also highlights how important payments system issues
have become to both central banks and the financial
services industry. Over the years values, volumes, and
the potential for risk have escalated to the point that
the consideration of payments systems is a key focus
in central bank meetings in Basle, in government policy-making
around the world, and in the board rooms of major financial
and nonfinancial companies everywhere. And it's not
just the massive impact of the wholesale business that
attracts attention and concern. Retail payments draw
keen interest both because of the potential presented
by technological change and because of the intense interest
of bank and nonbank competitors alike in capturing the
consumer and business market for new payment types and
information services.
Of course,
some of the keen interest in this conference reflects
the health if not the sheer global dominance of the
U.S. financial industry in general, and U.S. banks in
particular. The U.S. banking system is as well capitalized,
and profitable as it has been at any time in its history--a
model for and envy of a world that just ten or fifteen
years ago could find little to praise about it. How
has this been accomplished? Sound macroeconomic policies,
focused on low inflation and ever-lower budget deficits,
of course, are critical. But just as critical has been
the determination of U.S. banks and financial institutions
more generally to develop new products, improve risk
management techniques, adopt new technologies, and focus
on both service quality and efficiency as never before.
Reflecting this, the industry is experiencing a massive
and ongoing consolidation process, and has produced
institutions that thrive on global competition and seek
to maximize the profit potential in every aspect of
the business.
The
beneficial impact on the payments system of this progress
is obvious. Through central bank processing systems
alone now go $1.8 trillion in funds and book entry security
transfers, nearly 14 million ACH payments, and almost
$2.0 trillion in gross settlement entries for private
net settlement systems on a daily basis. This is done
with an ease and operational reliability that belie
the technical complexity involved, and that would have
been a dream only a few years ago. Levels of private
and Reserve Bank daylight credit are recognized, monitored,
and, if necessary, capped; extensive contingency facilities
exist; compatible message formats ease the exchange
of payments instructions between systems, and expanded
hours create greater overlap in the hours of international
payments systems facilitating timely settlement. Even
in the mundane world of check processing, new processing
techniques, digitized imaging, the gradual willingness
of banks to receive presentment data electronically
and the excitement about new retail payments methods
to replace the check auger well for a complete transformation
of the retail payments process. Moreover, as more institutions
see payments as a profit center, and as they are challenged
by new nonbank entrants, the inevitability of such a
transformation becomes obvious.
But
the more things have changed for the better, the more
they remain the same. Large, globally-oriented financial
institutions are linked by the payments system in a
web of interconnectedness that grows in complexity with
the size of the institutions involved. Systemic problems
may be less likely due to newly developed risk management
techniques and more sophisticated bank supervision,
but the cost of such problems, if it could ever calculated,
likely dwarfs any previous estimate. Moreover, given
technological change, systemic problems could spread
more quickly than ever before, dramatically increasing
the scale and scope of a problem, should one occur.
Expanded hours for funds transfers now exist, but does
the increasing importance of payments and securities
systems require 24 hour a day, seven day a week operations?
The development of real-time national gross settlement
systems is an important step forward for central banks
around the world. However, there is a natural tension
between such systems and the more efficient net settlement
processes that reduce the number of transactions and
improve efficiency, but make the size and nature of
the risks involved less transparent. Technology provides
the easy blurring of any distinction between electronic
wholesale and retail payments systems providing the
potential for values to grow in systems not broadly
designed for such use.
Finally,
despite all the industry's efforts for decades, we are
really not much closer to eliminating the paper involved
in retail payments--U.S. businesses and consumers wrote
65 billion checks last year, and the organizations represented
in this room had to process and clear them. It's a profitable
business, to be sure, and one that increasingly results
in faster availability and lower float, but one that
cries out for faster, easier-to-use and more electronic
alternatives that enhance information flow as well as
payment settlement. The ACH is nearly 30 years old,
but, except for significant progress by the U.S. Treasury,
and for direct payroll deposits, this form of electronic
payment has not reached its potential. Clearly, consumers
want more control over payment initiation, a fact that
has spurred innovation in any number of access technologies.
But which one of these offers the best prospects for
broad-based change? These are the challenges that have
brought you to this conference, and these are the challenges
that confound the private sector and the Federal Reserve
alike.
Amid
this environment of continual evolution and challenge,
what is the role of the Federal Reserve System? The
System began with the mandate to make nationwide payments
possible, and it has pursued that task as a regulator,
as a competitively-driven participant, and, as a catalyst
for change in such areas as payments system risk, MICR
encoding, ACH technology, and digitized image standards
and processing. The System's presence in the wholesale
arena is a given; today's markets would find it difficult
to function without the immediate finality and intraday
central bank credit those systems provide.
However,
with the advent of interstate banking, a nationwide
private sector retail payments system can and perhaps
should become predominant. Nonetheless, I would argue
that this development in no way diminishes the role
of the Federal Reserve. Rather, the need for central
bank involvement in the fundamental issues of payments
system accessibility, efficiency, and integrity is as
important as it ever has been given the extent and pace
of potential change. The System's processing role may
well diminish with the consolidation of the U.S. banking
system, but the more overriding central bank role in
the payments system must remain strong and evolve with
the industry. I see this evolution occurring in response
to four basic goals.
First,
the Federal Reserve needs to ensure that the U.S. payments
system supports economic growth. A highly efficient
payments system provides liquidity to fund the money
and capital markets that are the lifeblood of economic
progress. Indeed, these markets have been a foundation
for this country's growth and are unambiguously the
broadest, deepest, and, in many senses, the best in
the world. How can this important aspect of payments
systems be fostered and encouraged going forward? I
would argue that an efficient payments system has at
least two critical characteristics: open access and
a competitive, level playing field. Over the years,
working as a major participant and a regulator, I believe
the Federal Reserve has acted to increase access and
foster competition. I believe it should remain committed
to those important hallmarks in the future as well.
Can
these important payments system hallmarks be preserved
without a major operational role for the Reserve Banks?
Perhaps, but the commitment of the Federal Reserve to
providing access to the payments system at fair prices
and reasonable service levels is recognized by smaller
depository institutions as important. Moreover, in times
of turmoil or change, Reserve Bank processing facilities
provide an alternate source of service to private-sector
intermediaries that can help normalize payment flows.
Finally, by fairly competing with the private sector--as
I believe on balance the System has over the period
since the passage of the Monetary Control Act--the payments
system as a whole becomes more efficient. Going forward,
I believe the Federal Reserve must continue to work
diligently to ensure that competition is enhanced.
Now,
I think this can be done through regulation, and through
innovative service offerings. Several examples come
to mind. First, the Federal Reserve Board has requested
public comment on the pros and cons of extending the
presentment deadline for private-secctor same-day settlement.
This creates a larger daily window during which the
private sector arguably can compete directly with Reserve
Bank presentment services. There is a cost, especially
to the paying bank, but this is an extension of existing
regulatory policy that warrants consideration. On the
service side, the Reserve Banks are developing a new
automated net settlement process. This system will support
same-day finality over Fedwire for private sector net
settlement services and will enhance the finality and
ease of use of such services. This should provide a
basis for the development of new depository institution
services that provide options to the use of Federal
Reserve payment services. The Reserve Banks are also
working closely with their customers and other constituencies
to develop and deliver innovative national and local
check services and enhanced ACH services that will help
the banking industry respond effectively to their corporate
and retail customers.
Finally,
innovation in processes of both initiating and accessing
payment networks abounds as a result of technological
change. We see expanding use of debit cards, smart cards,
and internet transactions, to cite a few examples. I
believe the Federal Reserve needs to understand the
nature of this innovation and to continually evaluate
whether the new products and systems act to strengthen
the payments system or, potentially, to weaken it. I
do not believe that this calls necessarily for either
additional regulation or a Reserve Bank operational
presence. As these instruments and payments methods
evolve, if abuses or public policy concerns result,
regulatory issues related to consumer protection, privacy
and security may need to be considered.
In addition,
I do not rule out a Federal Reserve role in providing
leadership in the tough issues of standards-setting,
and, perhaps, some form of back-office service for which
it may be, at least initially, the best alternative.
One example that comes to mind here might be the provision
of image archive services--if image technology were
to be used more extensively in either the forward collection
or return process. For a time, it might be possible
for the Reserve Banks to leverage the knowledge and
technology acquired to support Treasury digitized image
efforts, speeding the absorption of this technology
and potentially developing a market for other competitors.
As a
second goal, the Federal Reserve should ensure that
payments system risk is well managed, both domestically
and internationally. Here, as I noted earlier, we've
come a long way, both in the world in general, and in
the U.S. payment system particularly. But I also would
argue that we cannot afford to be complacent.
Several
areas strike me as important for ongoing risk management
work. Real-time gross settlement systems have come into
being in most of the industrialized world, but progress
is slower in developing and transitional countries.
Private sector net settlement systems continue to offer
much in the way of transaction efficiency and lower
intraday liquidity requirements and are bound to be
attractive for those reasons. Such systems can make
risks less transparent than they would be on central
bank books, but the trade-off of risk and cost is not
easily assessed. The Federal Reserve's new net settlement
service may provide a hybrid alternative here that can
address both efficiency and risk concerns.
Hours
of system operation need to be evaluated to ensure support
for the continuing increase in traffic and risk. Retail
electronic payments systems need to be viewed on a continuum
with wholesale systems, with an eye to ensuring that
transaction pricing and service levels do not have the
unintended effect of increasing risk. Finally, data
security is a critical element in risk management and
I believe the Federal Reserve must remain committed
to the search for better and better methods of safeguarding
electronic transactions.
As a
third goal, the Federal Reserve should ensure that payments
systems are resilient in the face of expected and unexpected
crises. The major challenge to system resiliency facing
the world is preparing and implementing the systems
needed for century date change. Reserve Bank payments
systems are on track to becoming century date compliant
by mid-year 1998, and at that time the complex period
of customer testing will formally begin. Customer testing
will be extremely important. It is essential that you
test your critical systems, including your interfaces
with Reserve Banks, as early and as comprehensively
as possible.
On the
regulatory side, the System has issued advisories alerting
depository institution management to risks and establishing
compliance benchmarks and required reporting. Every
supervised institution will be examined for year 2000
readiness by June 1998, and this will continue until
the millennium change. The Federal Reserve is also studying
contingency scenarios, aware that no matter how perfect
the planning is, something can go wrong. Knowing how
to respond, and what can and cannot be done is important,
both as we make progress in implementation and face
the reality of January 1, 2001.
Finally,
last, but certainly not least on my list of goals, the
Federal Reserve must ensure that it works with the industry
in mutually shaping the payments system of the future.
Last year, the Rivlin Committee asked private-sector
payments system participants to consider five scenarios
for Federal Reserve involvement in the retail payments
system--from exiting to a more proactive operational
leadership role. In over 50 meetings nationwide, payments
system participants told System management over and
over again that the Federal Reserve should remain a
competitive provider of retail services for the good
of the overall payments process, and develop a stronger
leadership role in improving that process and moving
retail payments to electronic form.
Of necessity,
such a leadership role hinges on the ability to coordinate
disparate players around a series of critical issues,
and establish appropriate goals for retail payments
system development. Challenges abound: how to educate
the consumer about the advantages of electronic payments;
how to sort through the pluses and minuses of dynamic,
competing technologies, and how to coordinate among
the participants of a very decentralized network of
more than 10,000 banks and other service providers.
I believe
the Federal Reserve can be critical here as collaborator
and educator. Since 1995, the Federal Reserve in collaboration
with NACHA, the local ACH Associations, the U.S. Treasury,
and the Social Security Administration has carried out
marketing campaigns to financial institutions, selected
industry sectors and non-profits about the benefits
of direct deposit and direct payment. In the wake of
the Rivlin effort, we will engage further in customer-focused
ACH market research to better understand the barriers
to ACH use and how to fashion incentives that will produce
a broader user base.
In the
area of emerging payments, the work of the Rivlin Committee
will continue. The Committee will work with the industry
to form a senior-level advisory group to advance the
mutual understanding of the cost-benefit trade-offs
of broad-based retail payments change, and the various
forms in which such change could occur. The Federal
Reserve's current efforts with the Treasury on its EFT99
mandate, on financial EDI, and on an E-check pilot will
certainly be useful here in informing both the System
and the industry of the operational and market realities
of these new products.
In closing,
I think we would all agree that the pace of change in
the payments system is as fast and daunting as at any
time in recent memory. In the face of such change, it's
tempting to cling to old models and roles as an island
of stability. However, to do so would be to thwart the
benefits change can bring. I believe the Federal Reserve,
no less than the private sector, must embrace the changes
taking place but with a clear focus on the fundamentals--accessibility,
efficiency, and integrity. In that regard, working with
the industry becomes ever more important. Models of
partnership between the System and the industry have
been established over the years--now is the time to
carry these forward into the emerging payments world.
As I see it, the Federal Reserve can work with you:
- as a mediator, building consensus
through operational experience and through work on
such often overlooked areas as standards development;
- as a co-innovator, bringing
technology and new and enhanced services to participants
in new ways;
- as a technology developer,
applying the benefits of image efforts for the Treasury
to commercial check processes;
- as a co-educator, teaching
depository institutions the benefits of financial
EDI, increasing the use of electronic payments, and
working to increase corporate and consumer knowledge
and use of the ACH and other forms of electronic payments;
and
- as a collaborator, in assessing
market needs, trends, regulatory needs, if any, in
defining the goals and the framework of the U.S. payments
system of the future.
Thank
you.
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