Ladies and Gentlemen: I write as an interested person1 to petition the Board of Governors of the Federal Reserve System (Fed) under Section 553 (e) of the Administrative Procedures Act to engage and solicit public comments on a rulemaking process to shorten maximum permissible hold times for checks and funds deposited by customers, as required under the Expedited Funds Availability Act. This request is being submitted to the Consumer Financial Protection Bureau (CFPB) as under current law, the Fed and the Director of the CFPB are jointly responsible for this regulation.2
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- Acknowledgements and disclosures
- The Brookings Institution is financed through the support of a diverse array of foundations, corporations, governments, individuals, as well as an endowment. A list of donors can be found in our annual reports published online here. The findings, interpretations, and conclusions in this report are solely those of its author(s) and are not influenced by any donation.
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Table of Contents
- Klein Center on Regulation and Markets Brookings 1022024 1
- Regulators Have an Obligation to Act 1
- Klein Center on Regulation and Markets Brookings 1022024 2
- Klein Center on Regulation and Markets Brookings 1022024 3
- Klein Center on Regulation and Markets Brookings 1022024 4
- Delayed Payments Exacerbate Inequality 4
- Klein Center on Regulation and Markets Brookings 1022024 5
- Klein Center on Regulation and Markets Brookings 1022024 6
- Klein Center on Regulation and Markets Brookings 1022024 7
- The Benefits of Shortening Hold Times Real-Time Payments Are the Right Solution 7
- Klein Center on Regulation and Markets Brookings 1022024 8
- America Is a Global Outlier 8
- Klein Center on Regulation and Markets Brookings 1022024 9
- Addressing Arguments Against Faster Payments 9
- Klein Center on Regulation and Markets Brookings 1022024 10
- Conclusion 10
- Klein Center on Regulation and Markets Brookings 1022024 11
