September 9, 2021

The National Consumer Law Center (NCLC) (on behalf of its low-income clients), the National Community Reinvestment Coalition (NCRC) and the National Consumers League (NCL) submitted comments to the Federal Reserve Board (FRB) on its proposed rules for implementing the FedNow faster payment system. 

The groups expressed significant concerns that FedNow, under the proposed Regulation J (“Reg J”), will not be safe for consumers and other small users. They urge the FRB not to launch the FedNow service until it is safe for small users, including protection against fraud in the inducement and sender mistakes. They also urge the FRB to address specific parts of the proposed Reg J that are inappropriate for consumers and will cause confusion, that will impede financial institutions from preventing and remedying fraud and errors, that conflict with Regulation E, and that leave consumers and other users without a reliable right to the speed that the system promises.