Guest authored by Thomas
Wade, Director of Financial Services Policy at AAF
The summer heat in the U.S. capital may be the only plausible reason for one
odd notion that has seized imaginations in Congress: that the Federal Reserve
build and operate a real-time payments platform. The Fed has been considering
building such a system for a while, and a couple of bills were recently
introduced in Congress, notably including one by presidential candidate Senator
Warren, that would compel the Fed to do so. On Thursday of last week we
received the clearest sign yet in the form of a letter from Fed Chairman Jerome
Powell to members of the U.S. Senate in which he noted that the Fed
is “seriously considering” the matter and set out the Fed’s justifications for
doing so.
A real-time payments system would be unquestionably a public good. Such a
system would eliminate the lag that currently exists for many financial
transactions—a lag that leads to $15 million in overdraft fees, $9 million
in payday lending, and other costs for both
individuals and businesses. But the idea that the Fed should build this system
has numerous, fatal flaws.
To begin, it is not clear why the Fed should build a new system when the
solution already exists in the market. In 2017 The Clearing House, with the
Fed’s support, rolled out a real-time payments system that currently supports
half of all U.S. accounts and is expected to have total coverage by 2020. It
seems odd that this should be a priority for the Fed at a time when it has
considerably more pressing concerns.
Further, such a real-time payments platform appears to be outside of the Fed’s
legal mandate. The scope of the Fed’s powers in this arena is determined by the 1980 Monetary Control Act, which notes
that the Fed should intervene only if “the service is one that other providers
alone cannot be expected to provide with reasonable effectiveness, scope, and
equity.” Although adoption of a real-time payments system has been slow relative
to other nations, there is simply no evidence of a market failure that would
justify the Fed’s intervention.
To participate in, supervise, and regulate the financial system simultaneously
is an overwhelming conflict of interest. In a close parallel with what is being
proposed here, the Fed provides automated clearing house services while also
regulating the industry, and the Fed has systematically lowered its prices to
capture the largest customers at the expense of both its competitors and smaller
customers. Despite this precedent, proponents of the Fed’s involvement
ironically contend that the Fed is needed here to prevent
anti-consumer monopolistic practices—an argument difficult to make in any
event, given the range of private options in this space from companies
such as Mastercard, PayPal, Venmo, and Zelle.
And those aren’t even the practical concerns. Setting up another, entirely
duplicative payment system would potentially cost hundreds of millions of dollars, a
cost borne by the taxpayer. The time required to develop, test, and launch this
system would, optimistically, take the Fed between three and five years. And even after all
that, the Fed’s system, which would require significant new expertise at the
bank, would likely not be superior to ones currently being developed in the
private market, which has decades of experience and the
nimbleness a government body typically does not possess.
Government bodies entering public markets reduce competition, stopping or slowing
down innovation. The Fed’s actions have already slowed the adoption of a
real-time payment network, as businesses freeze development in the wake of the
uncertainty this unnecessary development has created. It can only be hoped that
cooler heads will prevail.
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