ICBA Policy Resolutions for 2013
Track I: Legislation and Regulation

PAYMENTS SYSTEMS ACCESS AND GOVERNANCE

Position 

• ICBA supports payment systems that are competitive, progressive, and secure, and that offer fair and open access to all community banks regardless of size and operational capability to meet the existing and evolving global payment needs of their customers.
  
  
• ICBA supports the Federal Reserve System in its dual role as payment systems regulator and provider of services. ICBA welcomes the new areas of strategic focus for Federal Reserve Financial Services that include collaborating with the entire payments supply chain, including innovators and end-users, to shape the end-user payment experience. ICBA will actively inject the community bank perspective in these and related areas of focus.
  
  
• ICBA encourages the Federal Reserve to use vigorously its new authority to identify and regulate systemically important payment, clearing and settlement systems.
  
  
• ICBA supports the important roles private-sector rulemaking organizations – payment card networks, and check and ACH clearing houses – play in developing and maintaining rules supporting fair, open and efficient access to payment systems.
  
  
• ICBA encourages the Federal Reserve Board and private-sector rulemaking and standards-setting bodies to uniformly enforce rules and timely refine rules to address new products and technologies, operational enhancements and other issues as they arise.
  
  
• ICBA supports public- and private-sector rulemaking bodies collaborating on ways to establish uniformity and efficiency between certain rules if appropriate and feasible.
  
  
• ICBA promotes active community banker involvement in payment rulemaking and standards-setting, operations and governance at the national and regional levels.

Background

Access. Community banks’ payment systems access must not be limited through the imposition of anti-competitive and discriminatory pricing or policies, membership requirements, standards, operating rules or technological barriers. The concentration of market power should not be used to force changes that would materially and adversely impact the competitive nature of our nation’s payments system.

Federal Reserve System. The ongoing dual payments role as a regulator and a provider of services allows the Federal Reserve to maintain efficient accessible, reliable, and safe payment systems for all financial services stakeholders. The new strategic focus for Federal Reserve’s Financial Services bodes well for all participants as the industry strives to meet the payments needs of consumers and businesses in a dynamic and innovative payments environment fueled by the emergence of smart-phones, tablets and other mobile devices. This strategy moves the Fed’s focus from the interbank payments market to the entire payments supply chain to shape the end-user payments experience. The Federal Reserve’s 10-year vision has three key principles: moving transactions faster from origination to settlement; creating a more efficient industry; and supporting an array of payment instruments that satisfy consumer preferences.

Private-Sector Governance. Given that private sector rules govern the ACH, payment card networks, and check clearing houses, it is vital for community banks to participate in the rulemaking, operations, and governance of these organizations, particularly at the regional level. At the national level, ICBA actively represents the community bank perspective before NACHA --The Electronic Payments Association as new ACH rules and innovative products are vetted and implemented. ICBA Bancard representatives are active participants in the Visa and MasterCard governing bodies. Additionally, ICBA and community bankers interject the community bank voice in the Electronic Check Clearing House Organization (ECCHO) rulemaking process governing check image exchange and the Accredited Standards Committee X9 mission to develop standards for the financial services industry.

Staff contacts: Viveca Ware, Cary Whaley

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