One of the great things about the holiday season is the time it provides to read and explore items that might otherwise be passed over and forgotten. This season, payment gurus had lots of eye candy in the form of 187 responses to the Federal Reserve Board’s request for comments on its Payment System Improvement Public Consultation paper, which were due no later than December 13th, just in time for leisure reading.
Although I didn’t review every submission, I did pick a range that I felt would suggest what a broad cross section of responders were suggesting, with enough breadth to provide a sense of where there might be common perspectives. I read responses from large and small financial institutions, industry associations (both banks and retailers), retailers, payments industry consultants, payments providers, etc.
There were common perspectives where I thought I’d find them, and one or two areas where it’s clear the payments industry is converging on consensus that will drive step function improvement, most notably around the potential for ISO 20022, the standard for financial services messaging.
Not surprisingly, there seems to be no general agreement among respondents about whether the United States payments industry has fundamental problems or not. Legacy players, where they saw issues (and not all did), seem sure that the free market can solve them in a timely fashion. Others see the United States payment system slipping behind those of other developed countries with eventual significant economic consequences if no steps are taken to move forward in a decisive manner.
I found the divergence in perspectives around the Fed’s role in developing payment futures quite telling. Traditional payment system drivers (financial institutions, the major credit card brands, and most – but not all – financial services centric industry associations) believe the Fed might serve as a focus point and facilitator to one degree or another. But many others think the Fed should be firmly in the driver’s seat going forward, and believe that the payments environment in the United States is so fragmented that short of the Fed leading the charge toward a near real time payments environment any material progress will be elusive.
Another area of predictable disagreement is around the question of whether the kind of near real-time payments environment the Fed posited can be derived from existing infrastructure or requires new, purpose-built systems. Here, discussion tended to be more parochial, with respondents – where they had it – touting their particular infrastructure as the best go-forward alternative.
One area where there might have been far more discussion was around the fraud consequences of near real-time settlement in a ubiquitously available payments environment. Many respondents mentioned the issue, few really explored it, and that’s unfortunate because – at least in my view – it’s an overarching concern.
Finally, I’ll confess that I found one or two responses just plain fun, hard as that may be to believe. These tended to be sometimes novel-like in their narrative, occasionally highlighting industry events sometimes best left unexplored on websites like the Fed’s, all to make a point, and usually with great effectiveness. Who said payments reading has to be dull?
For more than 35 years, Santa Fe Group Senior Consultant, Gary Roboff, contributed his outstanding talents to the financial services industry, and in particular to financial services payments systems. Gary has focused on such issues as privacy and information utilization, business frameworks, changes in the payments and settlement systems, and standards for emerging e-commerce applications. He has chaired the Electronic Funds Transfer Association (EFTA) Board of Directors and was a founder of the International Security Trust and Privacy Alliance (ISTPA), serving as Vice Chair of its Board.