The goal of reducing the number of paper checks sent by and to the federal government and increasing the use of electronic payments in both directions is a worthy one. Checks sent through the mail present many issues, including their slow speed and the risks of loss, theft, and fraud. At the same time, there are multiple reasons why people do not use electronic payments to or from the federal government today, and Treasury must address those reasons in order to make electronic payments work well, to increase adoption, and to provide adjustments to ensure that everyone can access electronic payments.
In these comments, we urge Treasury to:
- Conduct broader public outreach, including to stakeholders representing constituencies with different needs, to get their input and assistance.
- Use the success of the transition to electronic payments for Social Security and other recurring payments as a model and retain existing exceptions for those payments.
- Reduce unbanked rates, limit overdraft fees, and promote the BankOn program.
- For one-time payments to individuals, consider dos and don’ts and learn from the COVID stimulus payment experience.
- For payments by individuals, consider the challenges faced by people without bank accounts or internet access or who are not comfortable making electronic payments because of their age, their location, a disability, or other barriers.
- Consider using the Post Office, community action agencies, counselors, and others to ensure all individuals can send and receive funds.
- Protect and respect privacy.
- Include an exception process.
- Provide information through various channels in a clear, conspicuous, and readily accessible manner, including in multiple languages.
- Allow a meaningful transition period.
- Not use stablecoins, crypto-assets, or any other uninsured method of disbursing funds.
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