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TCH Comments on Proposed Change to the Federal Reserve Policy on Payment System Risk

The Clearing House (TCH) submitted a comment letter to the Fed in response to the potential change that would provide for real-time monitoring of all Fedwire fund transfers and rejection of transfers that would breach the Fedwire sender’s net debit cap. In the letter, TCH supports the reduction of risk posed to Federal Reserve Banks and Fedwire senders by Fedwire transfers that would breach a bank’s net debit cap. However, TCH encourages the Fed to consider alternatives to payment rejection that would be consistent with the objectives of Expanded Monitoring. TCH also suggests that the Board engage with Fedwire senders to explore other tools that might be employed to prevent and detect fraud.