Federal Reserve Board invites public comment on proposal that would allow U.S. banks and credit unions to use intermediaries to transfer funds through the FedNow Service

Washington D.C. – The Federal Reserve Board announced on Wednesday, April 8, 2026, an invitation for public comment on a pivotal proposal designed to significantly broaden the utility and reach of the FedNow Service. This strategic move aims to enable U.S. banks and credit unions to leverage intermediaries for the transfer of funds through the instant payment system, marking a substantial evolution in its capabilities. The proposal, officially released for public review, is expected to catalyze new private sector use cases and enhance the efficiency of both domestic and international financial transactions.

The core of the Federal Reserve’s proposal revolves around introducing greater flexibility into the FedNow Service’s operational framework. Currently, the FedNow Service, which launched in July 2023, facilitates direct transfers solely between two participating U.S. financial institutions. This limitation, while ensuring simplicity and directness in initial implementation, has constrained its application in more complex payment scenarios, particularly those involving multiple parties or cross-border elements. The new regulatory amendment seeks to remove this restriction by permitting the involvement of third-party intermediaries.

This expansion is specifically envisioned to support novel applications within the financial ecosystem. A primary example highlighted by the Federal Reserve is the facilitation of international cross-border payments. Under the proposed framework, U.S. banks could utilize FedNow to transact with correspondent banks, thereby streamlining the international leg of a cross-border transfer. This capability is poised to address long-standing inefficiencies, high costs, and delays inherent in traditional cross-border payment mechanisms, which often rely on a convoluted chain of intermediaries and disparate payment rails.

The Genesis of FedNow: A National Imperative for Instant Payments

To fully appreciate the significance of this proposal, it is crucial to understand the context and objectives behind the FedNow Service itself. The journey toward a ubiquitous instant payment system in the U.S. has been a multi-year endeavor, driven by a global shift towards real-time transactions and a recognition of the competitive and economic benefits they offer. Prior to FedNow, the U.S. payment landscape, particularly for non-urgent transactions, was characterized by batch processing and delayed settlement, often taking days for funds to clear.

The Federal Reserve initiated the "Faster Payments Task Force" in 2015, bringing together diverse stakeholders from across the financial industry to identify and evaluate approaches for achieving faster payments. This initiative culminated in the decision to develop FedNow, an interbank 24/7/365 real-time gross settlement (RTGS) service with integrated clearing functionality. Its objectives were clear: provide safe, efficient, and accessible instant payment services to financial institutions of all sizes, foster innovation, and promote financial inclusion.

Launched on July 20, 2023, FedNow enabled participating financial institutions to send and receive payments instantly, any time of day, any day of the year. This represented a monumental shift, offering immediate availability of funds for recipients, enhanced liquidity management for businesses, and greater financial control for consumers. By early 2026, the service had steadily expanded its reach, connecting hundreds of financial institutions, from large national banks to smaller community banks and credit unions, enabling a growing volume of instant transactions across the nation. However, the initial design focused predominantly on domestic, bank-to-bank transfers, setting the stage for the current proposal to unlock its broader potential.

Addressing the Complexities of Cross-Border Payments

The global cross-border payments market is a colossal and rapidly expanding sector, estimated to exceed $150 trillion annually and projected to grow substantially in the coming years. Despite its scale, this market has historically been plagued by structural inefficiencies. Traditional methods often involve multiple correspondent banks, each taking a fee and adding to the processing time. This leads to opaque costs, unpredictable delivery times, and a lack of real-time visibility for both senders and receivers. For individuals sending remittances, or businesses conducting international trade, these inefficiencies translate into higher operational costs, delayed supply chains, and reduced competitiveness.

The Federal Reserve’s proposal directly targets these pain points by envisioning FedNow as a critical conduit for the international portion of a cross-border payment. In practice, this could mean a U.S. bank initiating a payment via FedNow to a correspondent bank in the U.S., which then leverages its international network to complete the payment to a beneficiary abroad. Crucially, the initial FedNow leg of this transaction would be instant and final, providing certainty and speed that is often absent in the current system.

This approach offers several distinct advantages. Firstly, it would accelerate the domestic leg of international payments, reducing the overall end-to-end transaction time. Secondly, by integrating with a robust instant payment rail, it could foster greater competition and innovation among correspondent banks and fintech providers offering cross-border solutions. Thirdly, it could potentially lower costs for consumers and businesses by streamlining the payment process and reducing the number of intermediaries or the time funds are held in transit.

Inferred Industry Reactions and Support

The proposal is anticipated to be met with broad support from various stakeholders across the financial industry, albeit with nuanced considerations. Large commercial banks, many of whom already operate extensive correspondent banking networks, would likely welcome the increased flexibility. It could allow them to offer faster, more competitive cross-border services to their clients, potentially attracting new business and improving customer satisfaction. For these institutions, integrating FedNow into their existing international payment infrastructure could represent an operational enhancement and a strategic advantage.

Community banks and credit unions, which might have limited direct international payment capabilities, could particularly benefit. By partnering with larger correspondent banks that are FedNow participants and also have international reach, smaller institutions could offer their customers access to faster cross-border payments without needing to build out their own complex global infrastructure. This levels the playing field, enhancing their competitiveness and enabling them to better serve their local communities, including those with international ties or small businesses engaged in global trade. Industry associations like the American Bankers Association (ABA) and the Credit Union National Association (CUNA) are expected to voice support for measures that expand access to efficient payment systems for their members.

Fintech innovators and payment service providers are also likely to view this proposal favorably. Many fintech companies specialize in optimizing cross-border payments, leveraging technology to reduce costs and increase speed. The ability to use FedNow as a reliable, instant domestic component of their international payment flows could unlock new business models, foster partnerships, and accelerate the development of innovative payment solutions. This could lead to a proliferation of user-friendly, transparent, and cost-effective services for consumers and businesses engaging in international transactions.

However, industry participants will also be closely scrutinizing the details of the implementation, particularly regarding compliance and risk management. Expanding the use of FedNow to facilitate payments involving intermediaries and potentially leading to cross-border flows necessitates robust measures against money laundering (AML), terrorist financing (CFT), and other illicit activities. The Federal Reserve will need to ensure that the regulatory framework adequately addresses these concerns without stifling innovation or imposing undue burdens on financial institutions.

Regulatory Oversight and Risk Management

The Federal Reserve Board’s invitation for public comment underscores its commitment to a transparent and consultative regulatory process. The proposed amendment to Regulation J, which governs the collection of checks and other items by Federal Reserve Banks and funds transfers through Fedwire Funds Service and FedNow Service, will be carefully vetted. Regulatory bodies worldwide, including the Financial Action Task Force (FATF), continuously emphasize the importance of robust AML/CFT controls in payment systems. As FedNow’s capabilities expand, so too will the need for vigilance and cooperation among financial institutions and regulators.

The proposal will likely necessitate clear guidelines on the roles and responsibilities of intermediaries, particularly concerning due diligence, transaction monitoring, and data sharing. The Fed’s objective is to strike a balance: enabling innovation and efficiency while upholding the safety, soundness, and integrity of the U.S. financial system. Cybersecurity considerations will also be paramount, given the real-time nature of FedNow transactions and the potential for increased attack surfaces with broader intermediary involvement.

Broader Economic and Geopolitical Implications

Beyond the immediate operational benefits, the Federal Reserve’s proposal carries significant broader economic and geopolitical implications. By enhancing the efficiency of cross-border payments, the U.S. financial system further solidifies its position as a global leader in payment innovation. This can contribute to the continued strength and international appeal of the U.S. dollar, facilitating global trade and investment. Faster, cheaper, and more transparent international payments can boost economic growth, support small and medium-sized enterprises (SMEs) engaged in global commerce, and improve financial inclusion for diaspora communities relying on remittances.

Furthermore, as central banks worldwide explore and implement their own instant payment systems and even central bank digital currencies (CBDCs), the U.S. commitment to modernizing its payment infrastructure remains critical for maintaining competitiveness. The FedNow Service, with this expanded intermediary capability, positions the U.S. to integrate more seamlessly with other advanced payment systems globally, fostering greater interoperability and reducing fragmentation in the international payment landscape. This move aligns with global initiatives, such as those promoted by the Bank for International Settlements (BIS), to enhance cross-border payments as a public good.

Next Steps and Public Engagement

The public comment period for this crucial proposal is set for 60 days following its publication in the Federal Register. This timeframe allows financial institutions, payment processors, fintech companies, consumer advocacy groups, and other interested parties to submit their feedback, insights, and concerns to the Federal Reserve Board. The Board will meticulously review all comments received, which will inform the final shape and implementation of the rule.

The formal Federal Register notice, titled "Collection of Checks and Other Items by Federal Reserve Banks and Funds Transfers Through the Fedwire Funds Service and the FedNow Service," provides the full legal and technical details of the proposed amendments. Interested parties can access the HTML or PDF versions of the notice and submit their comments through the Federal Reserve’s dedicated online portal. This public engagement phase is vital for ensuring that the final rule is comprehensive, addresses industry needs, and effectively mitigates potential risks.

Looking ahead, the evolution of the FedNow Service, particularly through initiatives like this intermediary proposal, signals a continuous commitment by the Federal Reserve to adapting the U.S. payment infrastructure to meet the demands of a rapidly digitizing global economy. The ability to leverage intermediaries will not only unlock new domestic use cases but will profoundly impact how the U.S. connects to and facilitates the trillions of dollars in cross-border payments that underpin global commerce and personal remittances. This proposal represents a significant step towards a more interconnected, efficient, and resilient global financial system, with the FedNow Service playing an increasingly central role.

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