Management of Federal Agency Disbursements

PaymentsFirst, representing a group of financial institutions, supports the proposal to amend regulations regarding federal agency disbursements. They argue that requiring agencies to approve individual hardship waivers will help minimize unnecessary check payments and reduce associated costs and risks.

INFiN, a national trade association representing consumer financial services providers, opposes the proposed rule because it lacks sufficient waivers for unbanked, underbanked, and elderly individuals who rely on paper checks. They argue that the rule disproportionately harms vulnerable populations and advocate for codified waivers and a public-private partnership to ensure safe benefit delivery.

The Bank Policy Institute, The Clearing House Association, and the Consumer Bankers Association support the proposed rule to reduce federal government disbursements made by paper checks to improve security and modernize payment infrastructure. They recommend that the Treasury expand its use of private-sector electronic payment networks, enhance fraud detection capabilities, and explore account number tokenization.

America’s Credit Unions supports the Treasury's proposal to transition Federal disbursements from paper checks to electronic funds transfers (EFTs). They argue that EFTs offer greater convenience, faster access to funds, and enhanced fraud protections while reducing operational burdens for financial institutions.

The Clearing House Payments Company L.L.C. supports the Treasury's proposal to modernize federal payments and recognize "instant payment networks" as electronic funds transfers. They advocate for technology-neutral language that includes private-sector wire-transfer systems and emphasize the importance of maintaining multiple payment rails to ensure operational resiliency.

The Independent Community Bankers of America (ICBA) supports the proposed rule to transition federal payments from paper checks to electronic delivery to reduce fraud and operational burdens. They request specific clarifications to ensure fair competition between bank and nonbank payment endpoints, practical exceptions for those who still need checks, and efficient approval processes for small businesses.

The Independent Community Bankers of America (ICBA) supports the Bureau of the Fiscal Service's proposal to transition federal agency payments from paper checks to electronic delivery. They argue that this shift reduces fraud risk and operational burdens for community banks, while requesting specific clarifications to ensure practical implementation and fair treatment of bank accounts.

Corporate One Federal Credit Union supports the proposed rule to transition federal disbursements from paper checks to electronic payments to reduce fraud, costs, and delays. They advocate for clear implementation support and the preservation of exceptions for recipients who face genuine barriers to electronic access.

Nacha, an organization representing the ACH Network and over 8,000 financial institutions, supports the proposed rule to eliminate paper check disbursements by federal agencies in favor of electronic payments. They advocate for narrowing specific waiver categories to ensure the goal of reducing checks is met and suggest expanding electronic payment requirements to government collections.

EPCOR, a not-for-profit payments association representing over 1,600 financial institutions, supports the proposal to limit paper check disbursements by federal agencies. They argue that transitioning to electronic payments will reduce fraud risk, align with industry trends toward real-time payments, and provide more predictable deposit flows.