Federal Reserve Board: Settlement of Faster Payments (November 7, 2019)

Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed real-time gross settlement system service (FedNow) that was announced earlier this year. FMI was pleased to submit comments in strong support of the proposal late last year, and we were excited to learn that the Board has decided to move forward with a real-time gross settlement system. The Board’s proposed “FedNow” system will be a welcome addition to the services already provided by the Board and will help drive both competition and innovation in the U.S. payments market.

November 7, 2019 Ann Misback Secretary Board of Governors of the Federal Reserve System th 20 Street and Constitution Avenue NW Washington, DC 20551 Re: Federal Reserve Actions To Support Interbank Settlement of Faster Payments; Notice and request for comment; Docket No. OP-1670 Dear Sir or Madam, Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed real-time gross settlement system service (FedNow) that was announced earlier this year. FMI was pleased to submit comments in strong support of the proposal late last year, and we were excited to learn that the Board has decided to move forward with a real-time gross settlement system. The Board’s proposed “FedNow” system will be a welcome addition to the services already provided by the Board and will help drive both competition and innovation in the U.S. payments market. The Food Marketing Institute (FMI) proudly advocates on behalf of the food retail industry. FMI’s U.S. members operate nearly 40,000 retail food stores and 25,000 pharmacies, representing a combined annual sales volume of almost $770 billion. Through programs in public affairs, food safety, research, education and industry relations, FMI offers resources and provides valuable benefits to more than 1,225 food retail and wholesale member companies in the United States and around the world. FMI membership covers the spectrum of diverse venues where food is sold, including single owner grocery stores, large multi-store supermarket chains and mixed retail stores. For more information, visit www.fmi.org and for information regarding the FMI foundation, visit www.fmifoundation.org. While FMI’s members are not financial institutions or payments processors, our members generate billions of payments every year both for consumer purchases and business to business payments. Our members have a vested interest in ensuring payments here in the U.S. move forward and advance similarly to the innovations, efficiencies and security we are seeing globally. As the FRB is aware, there has been a long struggle on the “end-user” side of the payments marketplace where many products and services are introduced into the market without much, if any, consultation with our industries, nor consideration for how they may work on the “end-user” side. We are very grateful to the FRB for engaging with us early and continually throughout the process. FMI and our members firmly believe strong, secure payment innovation November 7, 2019 must be driven with all stakeholders at the table and fully engaged in the process. Ann Misback As the request for comment notes, the Federal Reserve has a long history of provisioning Secretary services for payments and settlement that have helped advance and improve payments in the U.S. Board of Governors of the Federal Reserve System By implementing FedNow, the FRB will continue in its work of driving innovation and th 20 Street and Constitution Avenue NW competition in our payments system. FMI particularly appreciated the FRB’s recognition that by Washington, DC 20551 building a ubiquitous core functionality for real-time payments and settlement, banks, payment processors, and other providers could build and offer new end-user auxiliary services our Re: Federal Reserve Actions To Support Interbank Settlement of Faster members could utilize. With this piece in mind, FMI finds it essential that the groundwork the Payments; Notice and request for comment; Docket No. OP-1670 FRB will lay by launching FedNow ensure inclusion, equity, and drive competition in the payments space. Dear Sir or Madam, With these principles in mind, FMI would like to share a few thoughts and insights in response to Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal the questions posed. Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed real-time gross settlement system service (FedNow) that was announced earlier this year. FMI Service Pricing was pleased to submit comments in strong support of the proposal late last year, and we were excited to learn that the Board has decided to move forward with a real-time gross settlement The FRB has announced it will release both the fee structure and schedule before the launch of system. The Board’s proposed “FedNow” system will be a welcome addition to the services FedNow. FMI agrees with the FRB’s approach to a long-run cost recovery. This is a large already provided by the Board and will help drive both competition and innovation in the U.S. undertaking and a new service for the FRB. It is essential that it is done thoroughly and correctly, payments market. including the requirement for recovery of costs. Ensuring interoperability and opening the service to a wide array of existing and future use cases will all affect the long-term costs of the The Food Marketing Institute (FMI) proudly advocates on behalf of the food retail industry. service. Additionally, the FRB may need to factor in incentives to encourage early adoption of FMI’s U.S. members operate nearly 40,000 retail food stores and 25,000 pharmacies, the new system. representing a combined annual sales volume of almost $770 billion. Through programs in public affairs, food safety, research, education and industry relations, FMI offers resources and With that in mind, FMI requests the FRB establish a fee structure that is equally weighted provides valuable benefits to more than 1,225 food retail and wholesale member companies in between both senders and receivers of the payments. The value proposition for both sides of the the United States and around the world. FMI membership covers the spectrum of diverse venues transaction merit both equally shouldering the costs. where food is sold, including single owner grocery stores, large multi-store supermarket chains and mixed retail stores. For more information, visit www.fmi.org and for information regarding Directory Services the FMI foundation, visit www.fmifoundation.org. In the request for comment, the FRB outlines several potential directory service models it is While FMI’s members are not financial institutions or payments processors, our members considering. First, FMI is very supportive of a directory service that would allow retailers and generate billions of payments every year both for consumer purchases and business to business their customers to initiate, send and receive payments without exchanging account information payments. Our members have a vested interest in ensuring payments here in the U.S. move and instead using a more public identifier. This would require some sort of a directory service for forward and advance similarly to the innovations, efficiencies and security we are seeing the globally.banks Asto s the hareF Rthe B rise levaawant re,inf therormation e has bewithen a eloang ch otherstruggle . FMon I sthe uppor“endts -theuse Fr”R sBide builofding the and parunning ymentsa cmarentrkealitplzeadc edir wheectorre ymany serviceproducs that tsa allndows se ravicell vestt aerd e tinthirrd oducpartied esint to oc the ontrmaibutrkee tot without it. Cmuch,onsumer if any,s should consultbea tiable on with to accouesrs indus their trinfiesor, matinor con onsto iderensaurtion e itf oris choworre they ct and maycan worbe k updaon ted the “aes ndne-eusdeed.r” Oneside. c Wentre aalirez eved rdiry grecatortefyul s to ervicethe FwouldRB for e nsengaureging ubiquiwithty ausnd e aar cly leaandr, s ceonticurenua lly sthrtandoughout ardizatitheon pron ocdaesta s. sFeMctsI ,a making nd our membethem opers fn irtoml ay llbe velitteeved asndtrong, cre desenticuraeled papayment rties.innovation November 7, 2019 mus t be driven with all stakeholders at the table and fully engaged in the process. Fraud Prevention Services Ann Misback As the request for comment notes, the Federal Reserve has a long history of provisioning Secretary sFeMrviceI fulls yfor suppor paymentsts the aFnd edNowsettleme’s pnt roposthate had cveapa hebillpeity d ofadva reancl-eti me and moniimprtoroveing paofyments trans aincti the onsU a.nd S. Board of Governors of the Federal Reserve System Bthe y imabilplemeity tonti alerng t FpaedNowrticipating , the baFRnksB will of a cny ontiunusnueu in al itors sworuspek coft trdransiviangcti innovation ons. Furtheramornd e, it th 20 Street and Constitution Avenue NW csupporompetitts ion payein e ouconfr pairymentsmation besysfotem.re the FM trIa nspaarctiticon ularcly an abeppr ceomplciateed ted.the DueFRB to’s the recognitirrevocion abilthatity by of Washington, DC 20551 thesbuilding e transa aubiquictionstous, it is c orlogie fcuncal toti onarequility ref that or rethe al-tipme ayorpa cymentsan be a sasnd uresd ettthey lemeant,re indeebanksd , spaending yment the procfeundsssor sto , athe nd othercorre cprt paovyeidere. s could build and offer new end-user auxiliary services our Re: Federal Reserve Actions To Support Interbank Settlement of Faster membe rs could utilize. With this piece in mind, FMI finds it essential that the groundwork the Payments; Notice and request for comment; Docket No. OP-1670 FAdditiRB wilonal lay lly, byFM launcI advoching atesFe fdNowor strong ensurende -inclususer aion,uthentica equityti,on and at dthe rive timcompetite of enrionoll mentin the and paprioryments to mul spatipcle e. transactions that may require re-authentication depending on the risk of certain Dear Sir or Madam, transactions. W ith these principles in mind, FMI would like to share a few thoughts and insights in response to Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal Ethe choing questiourons pr posevioused. support for a strong and centralized directory service, customers and Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed businesses would not need to share sensitive account information, instead can initiate real-time gross settlement system service (FedNow) that was announced earlier this year. FMI trSearnsviceacti Ponsricing with something like a phone number or email address. However, we acknowledge was pleased to submit comments in strong support of the proposal late last year, and we were that account information will still need to be shared at other levels of the transaction. In that excited to learn that the Board has decided to move forward with a real-time gross settlement Tspahec eF,R FBM haI asdvoc announcates eford ita wilrequirl reeleamentse both that the all efndee -sustrucer tursenes aitnd ive scdaheta dule be tokenizbefore ethe d both launcwheh ofn system. The Board’s proposed “FedNow” system will be a welcome addition to the services in FedNowtransit. aFnd MIa ta grerset esa ndwith storthe ed Fin RBan’ sope apprn oasourchc to e mannea longr- rcun omplcosiant t recwithover ey.x isTtihisng isa pplia larcgeable already provided by the Board and will help drive both competition and innovation in the U.S. sundetandartaking rds. and a new service for the FRB. It is essential that it is done thoroughly and correctly, payments market. including the requirement for recovery of costs. Ensuring interoperability and opening the sGeerviceneral to Opea widerati onsarra and y of Govexisetirng nancand e future use cases will all affect the long-term costs of the The Food Marketing Institute (FMI) proudly advocates on behalf of the food retail industry. service. Additionally, the FRB may need to factor in incentives to encourage early adoption of FMI’s U.S. members operate nearly 40,000 retail food stores and 25,000 pharmacies, the In anedditw ionsys to tem.the questions in the request for comment, the FRB also asked for general representing a combined annual sales volume of almost $770 billion. Through programs in comments on all aspects of the proposed FedNow Service. Below are a few additional thoughts public affairs, food safety, research, education and industry relations, FMI offers resources and Wfrom ith thethat einnd mi-usnd,er peFMrspeI recquetives. ts the FRB establish a fee structure that is equally weighted provides valuable benefits to more than 1,225 food retail and wholesale member companies in between both senders and receivers of the payments. The value proposition for both sides of the the United States and around the world. FMI membership covers the spectrum of diverse venues trans1.a)c tiOpeon mn aend rit bothinclus equaive llgovey shoulderrnance ingwith the allc osstakets. holders is critical. As mentioned above, the where food is sold, including single owner grocery stores, large multi-store supermarket chains U.S. payments system has traditionally taken a top-down approach with products, and mixed retail stores. For more information, visit www.fmi.org and for information regarding Directorstanday Servrdsice asnd protocols all being centrally set by a closed group without the ability of all the FMI foundation, visit www.fmifoundation.org. stakeholders to participate and drive the outcome. FMI is a founding member of the In the reSqueecurst ef Pora ymentscomme nt,Pa rthe tnerFsRhip B (outlSPPines), whic seveh raal dvocpotential ates fordir cercetoatirngy s earn viceope modelsn and it is While FMI’s members are not financial institutions or payments processors, our members considertring.ans paFirresnt t, FsMtandaI is rved sreytt sing upporproctivees sof f ora dielecrectrtoronic y separviceyments that in wouldthe U. allSow . 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FMon I sthe uppor“endts -theuse Fr”R sBide builofding the and parunning ymentsOnea cmare posntrkeaslitpliblzeaedc aedirppr wheeoactorrceh ymany csould erviceprbeoducs that to levetsa allndrowsage se rathe vicell veFsatt saeterrd e tintPhirarymentsd oducpartied e Csint to ouncoc the ontil r(maibutFPrCkee) ,tot whicwithout it. h much,Consumer ifF Many,sI s ishould c aonsn aultcbetiave tiable on membewith to accour eofsrs ,indus theiras the trinf iesprorim, matinorary c on goveonsto iderrennsaanurticon ee body itf oris choworforre Fthey cet dNowand mayca. n Asworbe the k updaonFR ted the B a“se ndne-eusdeknowsed.r” Oneside., the c WentrFe PaaClirez waeved rsdiry f orgrecmed atortefyul as sto e ravice the dire FcwouldRt rBe sfultor e nseofngaur theging e ubiqui Faswithterty P aausndyments e aar cly lea aEndrf,f se cecontictiurveenuane ssll y sthrtandoughout ardizaCrittietheron ia, pr on whicocdaeshta s .wa sFeMcs tsIde ,a making vendloped our membethemjointl opey rsby fn ir the toml ay Fllabe vesterlitte evePd a aymentssndtrong, cre de sTeanticsurk aeled F paorcpayment e r(tiFePsT.innovation C ) and November 7, 2019 mus t beS dreciven ure Pwitaymentsh all stake Tasholderk Forcse a(t Sthe PTFtable). W hilaned FfullMIy did enganot ged pain rtithecipa prte ocin esthe s. FPTC, instead Fraud Pon revthe entiSon PTSeC,r wevice has d several of our members involved in both and worked on the final Ann Misback As the reefquefectist veforne cssomm criteernt ia.notes The ,F the PC Fise dea brraoal Rde asend rveinclu hass aive long group historwhicy ofh prrecovisentlioniy forngmed and Secretary FseMrviceI fullsinclude yfor suppor paymentss ststake the holder aFnd edNowsestt flemerom ’s pnt thrroposthatoughoute had cvea pa the hebillpepaity d ymenofadva retsanc le-ecti osme and ysmonitem.impr torAdditioveing paonaofyments trllay,ns itaincsti the onsU a.nd S. Board of Governors of the Federal Reserve System Bthe y imabilplemeitmembey tonti alerrng ship t FpaeisdNowrti opecipating n, ,the andbaF RitnkssB b willoa ofr da c ny isonti inclusunusnueu in ive al itorofs swor vusaperkious coft tr drindusansiviangctrti iesinnovation ons withi. Furn thertheamornd pa ymentse, it th 20 Street and Constitution Avenue NW csupporompetittss paion pacyeein . eF oucMonfrI pabeirymentsmation lieves the besysfFotem.RreB the cFaM n trIaleve nspaarrctiaticgeon ul athercly a n eaxpebeppr creomplticsiatee aend d ted.the str DueucFRturB to’es othe ref cthe ognitirreFvocPion C atobilthat ity by of Washington, DC 20551 thesbuilding e tradensali aubiquivectirons soluttous, itions is c orlogi that e fcuncacl atotin onaberequi imlity rplemeef that or rented the al-tipme aand yorpabe cymentsann efbeit a all sa snd surtaekesd ettholderthey lemeant,sr.e T indeebahisnks sd tr, ucspaending turyment e prthe ocfeundsssorcould sto , athe nd serothercveor raes c prat paovmodel yeidere. s f orcould opebuiln and d ainclusnd offive er nestanw daendrd -ussettering auxilin iarothery s earrviceeas sof our the Re: Federal Reserve Actions To Support Interbank Settlement of Faster memberpas cymentsould uti elicoszeys. Wtem ith aths isadvoc piecaeted in mifornd by, F the MI SfPindsP. it essential that the groundwork the Payments; Notice and request for comment; Docket No. OP-1670 AdditiFRB wilona l lay lly, byFM launcI advoching atesFe fdNowor strong ensurende -inclususer aion,uthentica equityti,on and at dthe rive timcompetite of enrionoll mentin the and prpaioryments2. to) FmulM sIpa tiepcncle e.our traansgeasc tithe onsF Rthat B to maycons reiderquir er arise-ing authenticathe propostion ed de$25,pending 000 tron anstheac tirison k liofm cite rftainor Dear Sir or Madam, transactiFonsedNo. w. While the current level mirrors the private sector real-time solution, it is low for W ith thesdaeil y prbusinciplesiness in to mbusind,ines FMs trI awouldnsfers lithat ke toin sourhar eindu a fesw try thoughcan bets hundr and insedsight of sthous in reasndspons ofe to Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal Ethe choing quesdolltiouronsa rpr spos, eifvious enotd. morsuppe.or FtM forI would a strong as k and that cethentr aFliRzBed wordirek cwith tory stheervice private, cus stomectorer spr aovidernd to Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed bus inessraeiss ewould the canot p to nemakeed to its haeveren smorensiteive appeacacliount ng finfor daormation,ily busines insstea to d buscan inesinitis atrte ansactions. real-time gross settlement system service (FedNow) that was announced earlier this year. FMI trSearnsviceacti Ponsricing with something like a phone number or email address. However, we acknowledge was pleased to submit comments in strong support of the proposal late last year, and we were that 3.ac) cFount edNowinfor smation hould includewill sti all snetandaed to rdizebe sd ha“rreequed at sothert for pa leveyment”ls of the featurtraens. aTchistion. fe aIturn that e would excited to learn that the Board has decided to move forward with a real-time gross settlement Tspahec eF,R FaBMll haow I asdvoc faornnounc aa tesretailer eford ita or wilre indiquirl revidualeleamentse both to that sethe and ll eafnde ree -quesustrucesrt tursfeorne s paaitnd ive yment,scdaheta dule inibeti tokenizbealifzoingre e the the d both launcwheh ofn system. The Board’s proposed “FedNow” system will be a welcome addition to the services Fin edNowtransittr. a aFnsnd MacIa tita on,grerset eto sa ndwith the s torpathe eyord Fin .R OncBan’ sopee a the pprn oasrourequechc to es t manneafor long pary- rment cun omplcosisiant t rreeccwitheoveived,r ey.x the isTtihispang isyora pplia larcacn geable pus h already provided by the Board and will help drive both competition and innovation in the U.S. sundetandartaking rdsthe . paayment nd a neto w the servicepaye feor c omplthe FeRtiBng . Ithet is etrsasnsentiacatil on.that Amongit is done other thor advaoughlyntage and s, ac orrectly, payments market. including standathe rredizequid rerment equesft orf orre cpaoveymentry of f ceosaturts.e E wilnsurl aing dd aintnothererope layerabilrit oyf avend rifopeicatiningon thatthe the sGeerviceneral pato Opeyora wide risati s eonsanding rra and y ofthe Govexisfundsetirng nanc to and ethe futur corer eusct epa cayesees. will all affect the long-term costs of the The Food Marketing Institute (FMI) proudly advocates on behalf of the food retail industry. service. Additionally, the FRB may need to factor in incentives to encourage early adoption of FMI’s U.S. members operate nearly 40,000 retail food stores and 25,000 pharmacies, Ithe n ane4.ddit)w Iionntersys to tem.opether a quebilitsyti isons es in sentithe al refqueor thest fsoruc ccomessment, of Fe dNowthe FR aBnd alswillo a sdkerive d foradopti geneonra la nd representing a combined annual sales volume of almost $770 billion. Through programs in commentsinnovation. on all as peFMctsI aofcknowle the proposdgese d that FedNowcompl eSte erintviceer.ope Berlow abilitary e may a few notaddit be ional feasiblthoughte at the s public affairs, food safety, research, education and industry relations, FMI offers resources and Wfrom ith thethat ini eintinda mil -uslauncnd,er peFh MrofspeI FrecequetidNowves. ts .the WitFh RthatB es in tablismind,h a FfeMe Is trreucquetusrets that the FisR eBqua dellvey lop weighta plan ed to provides valuable benefits to more than 1,225 food retail and wholesale member companies in be tween acboth hievese intndeerropes and rabilrecitey iverbetwes ofe the n FepadNowyment bos.th Thecur vareluent a prnd oposfuturiteion solutforions both ins idesthe marof the ket. the United States and around the world. FMI membership covers the spectrum of diverse venues trans1.a)c tiOpe on mn aend rit bothinclus equaive llgovey shoulderrnance ingwith the allc osstakets. holders is critical. As mentioned above, the where food is sold, including single owner grocery stores, large multi-store supermarket chains 5.) U.EaSse. paof ymentsuse for sthe ystem endha-usse trr aisdit esionally sential.take Endn -aus toper -adown doption apprwilloa cdeh terwith mine producthe stsuc, cess of and mixed retail stores. For more information, visit www.fmi.org and for information regarding DirectorsFtandaye dNowServrdsice. asInd f therprotocolse is a lac ak ll ofbe ing unifcoerntmiraty lly ins the et byus ae rc losexpeed riencgroup e, owithoutr large hurthe dlesabil itfory of the a ll the FMI foundation, visit www.fmifoundation.org. sctakeustomholderer to suti to lipazer tiFceipatedNow a,nd it willdrive rethe sultoutcome in a lack . FofM aIdopti is a fon.ound FMing I emembencourarge ofs the the FRB In the reSto queecdeursvet ef lop Pora ymentscsommtandae rnt,Pdizea rthe tnerd grFsRhip aBphica (outlSPl Pinesus), ewhicr s inteveh erraafal dvoccpotential es tahatest cfaordirn ceeracestoailtiry ngy bes ea rincorn viceope pormodelsn aandted intit iso While FMI’s members are not financial institutions or payments processors, our members considertrmobiing.ans pale Firrbaesnt tnking , FsMtandaI aisppli rved srceyatt tising upporonspr makingoctivees sof f orita ediealecrseierctrtor onic fory sceonsparviceymentsumer that s to in wouldtheutili U.z aellS the ow . 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FMon I sthe uppor“endts -theuse Fr”R sBide builofding the and par unning ymentsOnea cmare posntrkeaslitpliblzeaedc aedirppr wheeoactorrceh ymany csould erviceprbeoducs that to levetsa allndrowsage se rathe vicell veFsatt saeterrd e tintPhirarymentsd oducpartied e Csint to ouncoc the ontil r(maibutFPrCkee) ,tot whicwithout it. h much,CFMonsI thanksumer ifF Many,sI s the ishould c aonsFn eaultdecbetirave atialble on Rmembeewith sto eraveccour Beofsroas ,indus theirard s theaga trinf iesin prorim,f ormatinora rity sc on goveonscommto iderrennsitaanment urticon ee body itf to oris imchoworforprre oveFthey cet dNowa ound mayrc paa. n Asworymentsbe the k updaonF R ted the B sa“ysse ndnetem-eusdesknowse d.in r” Onethe side., U. the c WeSntr.Fe W PaaClireez swaevetrd onglyrsdiry f orgrecmed a tortefbeliyul aes sveto e ravice the FdiredNowe FcwouldRt rBe s fiultors ea nse ofmuchngaur theging e ubiqui -Fneasewithterdety d P aausprndymentsoduc e aar cly leat that aEndrf,f se cwillecontictiurve edrnuane ive ssll y sinnovation thrtandoughout ardizaCritatiethend ron ia, prc on whicompetitocdaeshta s .wa sFioneMcs ts Idein ,a making vendthatloped our spa membethemcjoie.ntl T haopey rsbynk fn ir the ytomlou ay Fllaabe gavesterliin tte evePfd ora aymentss ndtthe rong, coppore de sTeanticrstuniurk aeled F typaor cpayment to e r(stiFhaePsrT.einnovation C ou) ar nd November 7, 2019 musthoughtt beSs dr eon civen urFee dNowPwitaymentsh a allnd stake Thowasholderk weFor cesenvis a(t Sthe Pion TFtableit). beWing hilaned buil FfullMt,Iy imdid engaplemenot ged panted in rtitheciapand prte ocfuncin esthe sti.oning FPT.C W, inse looktead Ff orraud ward Pon rtoe vthe ceontintiSon PnuingTSeC,r we vto ice worhas d ks ewithvera l the of FourRB membe to ensurrse invol FedNowved in isboth a suc acnd esswor. ked on the final Ann Misback As the reefquefectist veforne cssomm criteernt ia.notes The ,F the PC Fise dea brraoal Rde asend rveinclu hass aive long group historwhicy ofh prrecovisentlioniy forngmed and Secretary FsIfeM ryouviceI full hasinclude yfveor suppor quepaymentsss stitstakeons the holder aabout Fnd edNowsesthestt flemerom ’es cpnt thrommroposthatoughoutee ntshad c veora pa the hewould billpepaity d ymenofliadvake rets aanc dditle-ecti osme aionalnd ysmonitem.im infpr torAdditioovermation,ing paonaofyments tr llpleaay,ns itasincseti the fonseel U a.nd S. Board of Governors of the Federal Reserve System Bthe fry eeima to bilplemecitmembeontacy tonti at lerrme ng ship t Fpa(ehwaisdNowrti opeclkeripating n, @,the afndmibaF Rit.onkssBr gb will).oa o fr da c ny isonti inclusunusnueu in ive al itorofs swor vusaperkious coft tr drindusansiviangctrti iesinnovation ons withi. Furn thertheamornd pa ymentse, it th 20 Street and Constitution Avenue NW csupporompetittss paion pacyeein . eF oucMonfrI pabeirymentsmation lieves the besysfFotem.RreB the cFaM n trIaleve nspaarrctiaticgeon ul athercly a n eaxpebeppr creomplticsiatee aend d ted.the str DueucFRturB to’es othe ref cthe ognitirreFvocPion C atobilthat ity by of Washington, DC 20551 Sthesbuilinceding e rtrealy,densali aubiquivectirons soluttous, itions is c orlogi that e fcuncacl atotin onaberequi imlity rplemeef that or rented the al-tipme aand yorpabe cymentsann efbeit a all sa snd surtaekesd ettholderthey lemeant,sr.e T indeebahisnks sd tr, ucspaending turyment e the pr ocfeundsssorcould sto , athe nd serothercveor raes c prat paovmodel yeidere. s f orcould opebuiln and d ainclusnd offive er nestanw daendrd -ussettering auxilin iarothery s earrviceeas sof our the Re: Federal Reserve Actions To Support Interbank Settlement of Faster membe rpas cymentsould uti elicoszeys. Wtem ith aths isadvoc piecaeted in mifornd by, F the MI SfPindsP. it essential that the groundwork the Payments; Notice and request for comment; Docket No. OP-1670 AdditiFRB wilona l lay lly, byFM launcI advoching atesFe fdNowor strong ensurende -inclususer aion,uthentica equityti,on and at dthe rive timcompetite of enrionoll mentin the and prpaioryments2. to) FmulM sIpa tiepcncle e.our traansgeasc tithe onsF Rthat B to maycons reiderquir er arise-ing authenticathe propostion ed de$25,pending 000 tron anstheac tirison k liofm cite rftainor Dear Sir or Madam, transactiFonsedNo. w. While the current level mirrors the private sector real-time solution, it is low for Hannah Walker W ith thesdaeil y prbusinciplesiness in to mbusind,ines FMs trI awouldnsfers lithat ke toin sourhar eindu a fesw try thoughcan bets hundr and insedsight of sthous in reasndspons ofe to Food Marketing Institute (FMI) would like to thank the Board of Governors of the Federal Victhe Echoing eque Prsdolletisourident,onsa rpr spos, e ifPvious eublnotd. ic morsAfuppfea.or iFrtsM forI would a strong as k and that cethentr aFliRzBed wordirek cwith tory stheervice private, cus stomectorer spr aovidernd to Reserve System (FRB) for the opportunity to share our thoughts and comments on the proposed businessraeiss ewould the canot p to nemakeed to its haeveren smorensiteive appeacacliount ng finfor daormation,ily busines insstea to d buscan inesinitis atrte ansactions. real-time gross settlement system service (FedNow) that was announced earlier this year. FMI trSearnsviceacti Ponsricing with something like a phone number or email address. However, we acknowledge was pleased to submit comments in strong support of the proposal late last year, and we were that 3.ac) cFount edNowinfor smation hould includewill sti all snetandaed to rdizebe sd ha“rreequed at sothert for pa leveyment”ls of the featurtraens. aTchistion. fe aIturn that e would excited to learn that the Board has decided to move forward with a real-time gross settlement Tspahec eF,R FaBMll haow I asdvoc faornnounc aa tesretailer eford ita or wilre indiquirl revidualeleamentse both to that sethe and ll eafnde ree -quesustrucesrt tursfeorne s paaitnd ive yment,scdaheta dule inibeti tokenizbealifzoingre e the the d both launcwheh ofn system. The Board’s proposed “FedNow” system will be a welcome addition to the services in FedNowtransittr. a aFnsnd MacIa tita on,grerset eto sa ndwith the s torpathe eyord Fin .R OncBan’ sopee a the pprn oasrourequechc to es t manneafor long pary- rment cun omplcosisiant t rreeccwitheoveived,r ey.x the isTtihispang isyora pplia larcacn geable pus h already provided by the Board and will help drive both competition and innovation in the U.S. sundetandartaking rdsthe . paayment nd a neto w the servicepaye feor c omplthe FeRtiBng . Ithet is etrsasnsentiacatil on.that Amongit is done other thor advaoughlyntage and s, ac orrectly, payments market. including standathe rredizequid rerment equesft orf orre cpaoveymentry of f ceosaturts.e E wilnsurl aing dd aintnothererope layerabilrit oyf avend rifopeicatiningon thatthe the sGeerviceneral pato Opeyora wide risati s eonsanding rra and y ofthe Govexisfundsetirng nanc to and ethe futur corer eusct epa cayesees. will all affect the long-term costs of the The Food Marketing Institute (FMI) proudly advocates on behalf of the food retail industry. service. Additionally, the FRB may need to factor in incentives to encourage early adoption of FMI’s U.S. members operate nearly 40,000 retail food stores and 25,000 pharmacies, Ithe n ane4.ddit)w Iionntersys to tem.opether a quebilitsyti isons es in sentithe al refqueor thest fsoruc ccomessment, of Fe dNowthe FR aBnd alswillo a sdkerive d foradopti geneonra la nd representing a combined annual sales volume of almost $770 billion. Through programs in commentsinnovation. on all as peFMctsI aofcknowle the proposdgese d that FedNowcompl eSte erintviceer.ope Berlow abilitary e may a few notaddit be ional feasiblthoughte at the s public affairs, food safety, research, education and industry relations, FMI offers resources and fWrom ith thethat ini eintinda mil -uslauncnd,er peFh MrofspeI FrecequetidNowves. ts .the WitFh RthatB es in tablismind,h a FfeMe Is trreucquetusrets that the FisR eBqua dellvey lop weighta plan ed to provides valuable benefits to more than 1,225 food retail and wholesale member companies in between acboth hievese intndeerropes and rabilrecitey iverbetwes ofe the n FepadNowyment bos.th Thecur vareluent a prnd oposfuturiteion solutforions both ins idesthe marof the ket. the United States and around the world. FMI membership covers the spectrum of diverse venues trans1.a)c tiOpe on mn aend rit bothinclus equaive llgovey shoulderrnance ingwith the allc osstakets. holders is critical. As mentioned above, the where food is sold, including single owner grocery stores, large multi-store supermarket chains 5.) U.EaSse. paof ymentsuse for sthe ystem endha-usse trr aisdit esionally sential.take Endn -aus toper -adown doption apprwilloa cdeh terwith mine producthe stsuc, cess of and mixed retail stores. For more information, visit www.fmi.org and for information regarding DirectorsFtandaye dNowServrdsice. asInd f therprotocolse is a lac ak ll ofbe ing unifcoerntmiraty lly ins the et byus ae rc losexpeed riencgroup e, owithoutr large hurthe dlesabil itfory of the a ll the FMI foundation, visit www.fmifoundation.org. sctakeustomholderer to suti to lipazer tiFceipatedNow a,nd it willdrive rethe sultoutcome in a lack . FofM aIdopti is a fon.ound FMing I emembencourarge ofs the the FRB In the reSto queecdeursvet ef lop Pora ymentscsommtandae rnt,Pdizea rthe tnerd grFsRhip aBphica (outlSPl Pinesus), ewhicr s inteveh erraafal dvoccpotential es tahatest cfaordirn ceeracestoailtiry ngy bes ea rincorn viceope pormodelsn aandted intit iso While FMI’s members are not financial institutions or payments processors, our members considertrmobiing.ans pale Firrbaesnt tnking , FsMtandaI aisppli rved srceyatt tising upporonspr makingoctivees sof f orita ediealecrseierctrtor onic fory sceonsparviceymentsumer that s to in wouldtheutili U.z aellS the ow . FMprreIoductailer stronglyt.s and generate billions of payments every year both for consumer purchases and business to business their cusbeFtomeliatureveeresss to that likein itthe siatetandaF,R srBedizend haasd ndasn e rcopporeurceeive opetunipan ymety APItontss f, osa uthenticawithoutter open etisxtandaon chamethodsnging rd-seattcing acnd ount wheusinfen r orintmationerfaces payments. Our members have a vested interest in ensuring payments here in the U.S. move and insteawillimd pleme usalling entincaourng moraFgeeedNow pubendli-usc. identi er conffieridenc. Thise a wond uld adoptirequiron. e some sort of a directory service for forward and advance similarly to the innovations, efficiencies and security we are seeing