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MCUA Comments to Federal Reserve on Payment System Risk Policy and Related Reg J Changes

The Missouri Credit Union Association (MCUA) recently submitted comment letters (to the Federal Reserve Board (Fed) on the Payment System Risk (PSR) Policy and related Regulation J proposed changes. The Fed proposed several changes to its PSR Policy and procedures for measuring intraday balances at financial institutions’ accounts at the Federal Reserve Banks.

In its letters, MCUA was concerned some financial institutions may be impacted by the proposed earlier posting times for automated clearing house (ACH) debits and commercial checks. If these changes are necessary, MCUA believes the Fed should minimize the costs and impact on credit unions, corporate credit unions, and other payment providers that may be affected, by providing additional information and resources, as well as adequate time for implementation.

Regarding the proposed same-day ACH principles, MCUA believes it would be helpful to provide additional opportunities for stakeholders to provide input in the future.