Comment on FR Doc # 2026-08278

On behalf of PaymentsFirst, thank you for the opportunity to provide feedback on this Request for Comment regarding Management of Federal Agency Disbursements. Our Rules and Operations Committee which is composed of representatives from financial institutions across the U.S. reviewed the proposal and provided feedback. We have compiled the comments into our response. Background The payments industry has been heavily involved with the need to migrate federal payments to electronic payments since the Debt Collection Improvement Act of 1996, also known as EFT 99. While we understand and support the need for situational waivers, there is a need to further reduce the unnecessary costs and risks associated with check payments. Reducing the number of check payments by one-third would result in savings of more than $40 million annually. Proposed Change to Regulation We agree with the proposal to amend the existing part 208 by eliminating or modifying certain waivers while possibly adding new waivers. The move to require the respective agencies to approve the individual hardship waivers will allow those agencies with the individual relationships to better determine the need. It is our hope that having the respective agencies verify the need for an exception as well as the reporting of their compliance to the guidelines will help them identify true hardship cases. As payment channels and rails have continued to expand, it is our hope that hardship cases can be minimized.