speeches · June 14, 2005
Regional President Speech
E. Gerald Corrigan · President
Payments System Issues and Challenges | Federal Reserve Bank of Minn... https://minneapolisfed.org/news-and-events/presidents-speeches/payment...
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Good morning. It's a pleasure to be here. I appreciate the
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opportunity to discuss payments issues with a group that's at the Banking in the Ninth
forefront of technological innovation for the financial services
industry. I've spent some time reflecting on how to add value to a
Connect
forum with the theme "The Road Ahead," and in that spirit, I will
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make three main points: Minneapolis Fed on Facebook
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First, although providers of payments services—including the
Fed—face many challenges, the overall state of the U.S.
payments system is excellent, and the economic benefits derived
from the system are enormous.
Second, the positive state of the payments system largely reflects
market forces, not government planning or intervention.
Third, given the current state of the payments system, the role of
markets in achieving this outcome, and the limitations on a central
body to address perceived problems, the Federal Reserve should
be quite careful before intervening in these markets.
I am, of course, speaking only for myself and not for others in the
Federal Reserve.
Overall State of Payments
I have been chair of Federal Reserve's Financial Services Policy
Committee (FSPC) for two years now, and at times this has been
a challenging responsibility. Consider where we in the Federal
Reserve have had to focus our efforts over these years:
Emphasizing efficiency and keeping prices for electronic
services low while offering improved quality as demanded by
customers;
Planning the "next generation" of our electronic services in
the midst of major changes in demand and in the technology
of supply; and
Reducing our infrastructure for the processing of checks at a
time when massive cost cutting by itself is insufficient to
recover costs.
Of course, this brief list ignores the myriad of specific projects and
initiatives covering a host of payments activities, but it is intended
to provide a high-level sense of priorities. I should note as well our
ongoing improvements in resiliency and in the security of our
systems, related both to the continued implications of the
post-9/11 world and to offering payments in an Internet
environment.
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The effort to downsize our infrastructure is particularly daunting at
times. We recognized belatedly that check volumes began a
pronounced and sustained decline sometime in the second half of
the 1990s, leaving us with excess processing capacity and a
significant financial deficit. I suspect some other providers find
themselves in similar circumstances.
But it would be a serious mistake, in my view, to confuse the
challenges that providers face with a true assessment of the state
of payments. As an economist, I would be worried if providers of a
service have what some call the "quiet life." That implies
monopoly pricing, lack of innovation, and other traits which may
benefit providers but which are not good for consumers, nor, most
likely, the economy.
In that vein, I sometimes think that those of us involved in
payments on a daily basis lose sight of the forest for the
trees—that is, we tend to focus excessively on challenges and fail
to appreciate how efficient and effective the system really is. After
all, the payments system supports our $11 trillion economy—it is
truly the plumbing which facilitates the multitude of transactions
our level of economic activity requires—and much of the time
producers and households give the payments system virtually no
thought whatsoever. Access, integrity, and effectiveness are
normally taken for granted, and that's all to the good.
I have the sense that I am not alone in taking this view. As part of
my FSPC role, I attend conferences such as this where the state
of payments is discussed, including the major meeting in October
of 2003 here in D.C. sponsored by the Federal Reserve. While we
all may have a "wish list" of desired improvements, a
comprehensive assessment of discussions at these conferences
reveals that from a public policy perspective the payments system
does not appear to be facing serious, fundamental problems. It
largely does what it is supposed to do and does it well, and it
seems able to adapt effectively to the changing needs of end
users.
Given this state of affairs, it is worth considering what has brought
us to this favorable position. In my view, it is giving markets
preeminence in determining the direction and evolution of the
payments system.
Role of Market Forces
The smooth functioning of and range of choices available in our
payments system are major accomplishments. While I think the
Federal Reserve has played a constructive role in this outcome,
we do not claim nor deserve the bulk of the credit—many
institutions contribute to the effectiveness and efficiency of the
U.S. payments system. Indeed, the credit should go to a system
which has the flexibility to adjust to the desires of households. All
the white papers in the world that called for an end to the paper
check did not produce that outcome. Instead, it is occurring
primarily in markets where the Federal Reserve has no role as a
service provider (for example, credit and debit cards) and as
households "spontaneously" change their behavior over time.
Taking this household-centric view may seem odd for a service
provider that has to recover costs. But because we in the Federal
Reserve wear two "hats"—participant and regulator—and
because we are a public policy institution as distinct from a private
sector provider, we have a special responsibility to view payments
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in the context of societal benefits and to promote the broad public
interest.
A practical implication of this analysis and stance is a
preference—from my perspective a very strong preference—to
permit market forces to shape payments system developments
insofar as possible. This preference is, after all, consistent with
the general principles we follow throughout our economic affairs.
There are certainly important roles for government to play in our
economy, but when the overall trend is positive—as it is for
payments—I don't believe there are significant gains from
government responses to every deviation from that trend along
the way. Uncertainty in the market during periods of transition and
a sense of unsettledness among providers as transitions are
worked through are not in themselves sufficient reasons for
government responses to sort these issues out ahead of natural
market processes. So what should be the role of the Fed?
Role of the Federal Reserve
I would expect that this audience would have natural sympathies
for the market-oriented views I have expressed, given your
experience and success in the private sector. And in that vein, you
may wonder why I even need to bring these themes up. Well,
because on occasion, some in the private sector seem to prefer
that we in the Federal Reserve take a more definitive and
aggressive approach, and specify with certainty (or as much
certainty as possible) our future plans, for example, with regard to
check offices, to business-to-business payments standards, to
security and privacy issues, and possibly even to interchange
fees. So let me be a bit more specific about why I think complying
with those requests in a way that would ostensibly reduce
uncertainty would often be a bad idea.
First, we do not possess perfect foresight. I am aware of one head
office building in the Federal Reserve designed in the late 1960s
on the premise that the "checkless society" was just around the
corner. It has turned out to be a very long corner indeed, and in
the meantime this District had to operate in a building ill-equipped
for high-volume check processing. Perhaps somewhat ironically,
we were subsequently surprised that check volumes actually
started to decline since our market intelligence did not pick up this
reversal in trend until several years after the fact. Recently, we
have witnessed lots of private sector innovation in converting
paper to electronics and in expanding the range of electronic
alternatives per se. It is possible that we underestimated the
ability of computing and communications technologies to make
electronics reliable, inexpensive, and accessible, especially in an
environment where end users are becoming increasingly familiar
and comfortable with the technology.
The second, and more compelling, consideration suggesting a
restrained role for the central bank in promoting payments system
change is the clear and legitimate lack of consensus surrounding
many important issues. This is, I think, evidence that market
forces are still sorting out these matters. Consistent with my
earlier observation, we generally want to leave resolution of
competing processes and products to the market when we can.
The hurdle confronting central bank innovation in payments
presumably should be quite high, requiring either convincing
evidence of market failure and/or the existence of barriers to
progress which will not otherwise be addressed. Further, for those
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"improvement opportunities" which have been identified, it is only
a bit of an exaggeration to say that, desirable though they may be,
each payments system participant would prefer that others make
the investment, bear the bulk of the costs, establish the new
processes, and work out whatever kinks arise.
The issue of standards-setting in payments provides an illustrative
case in point. Numerous participants have asserted that a
significant barrier to further expansion of electronic
payments—take business-to-business payments, for example—is
a lack of standards and therefore that a valuable role for the
Federal Reserve would be to intercede to resolve the matter. This
could be, but the literature on standards adoption does not
overwhelmingly support the efficacy of government intervention.
As my colleague Jim Lyon has pointed out: "The available
research provides relatively little reason for confidence that a
policymaker will be able to determine with certainty either the
correct standard to endorse or the proper time to endorse it.
Moreover, even if these issues could somehow be overcome, the
proper choice may depend on the relative importance attached to
the welfare of those who have already adopted one of the
competing standards choices and those who have yet to do so.
Further complicating the situation is the reality that some
standards may remain such for only a relatively short period of
time given the dynamic nature of technology." Thus, there would
seem to be a considerable burden of proof on a central bank
considering direct intervention to resolve conflicts over standards.
Another example of well-founded caution in my judgment is in the
area of fees associated with retail payments. Those who pay the
various fees associated with retail payments, whether they be
retailers, banks, or households, have in the past and sometimes
in the current period called on government to regulate those fees
because they are "too high" or, less frequently, "too low." But the
government cannot go on "gut feeling" in these cases. We must
rely on solid evidence that markets are failing, that current price
setting is reducing benefits that should accrue to society, and the
like. In my experience, that evidence is often lacking, the issues
are often more complex than immediately presented, and it is far
from obvious that government intervention will improve the
situation.
Even in cases where markets do not operate perfectly, we must
keep in mind the fact that there could be large costs to society
when the government is too prescriptive and proceeds too far too
quickly. These costs could manifest themselves in reduced
innovation, higher costs for payments services, and fewer
effective payments alternatives than would otherwise develop and
emerge if private sector participants are permitted to compete and
the winners to flourish. We have to be exceedingly careful that
central bank initiatives do not have a chilling effect on the private
sector.
Does this mean the central bank must never act? No. But where
there might be a role for the central bank, it is more likely to be in
productively encouraging reliance on market forces by facilitating
changes in the legal and regulatory infrastructure where it
appears to inhibit innovation. Federal Reserve support of Check
21 legislation is an example of such an approach, although it is far
too early to assess both the full ramifications of Check 21and how
rapidly and how far the move from paper to electronics will
proceed over the next several years. We in the Federal Reserve
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are committed to this evolution, and clearly we are in the midst of
reducing our check-processing infrastructure appreciably while
maintaining service to a broad and diverse base of customers.
Given current plans, we will have gone from 45 to 22 check-
processing locations by the end of next year. I think this is a
significant response to changing market conditions by any
"standard."
Still, it is fascinating to contemplate what more may have to be
done to achieve further electronification and to reduce our
commitment to the "old technology." Will significant price changes
and/or changes in processing windows and availability schedules
be required and, if so, can these steps be justified on cost-benefit
grounds? These questions are simply illustrative of issues we
confront as the marketplace and technology continue to evolve.
Conclusion
Let me quickly summarize these remarks before inviting your
comments, questions, and objections. There is no doubt that
payments system change continues apace. It is preferable from
my perspective that such change be driven by market forces, and
it appears that largely has been the case. Central bank
intervention should be reserved for cases characterized by broad
and compelling societal benefits.
At the same time we, like you, have a business to run, and in this
regard there is no shortage of practical, on-the-ground challenges.
I highlighted some facets of check processing this morning
because they are illustrative of these challenges and of policy
considerations as well. As the downsizing of our check
infrastructure, the Check 21 legislation and implementation, and
the ongoing substitution of electronics for paper demonstrate,
there remain important questions about ultimate equilibrium in this
segment of the business. And there are important policy matters
for the Federal Reserve to determine: the scale of our long-run
commitment to this business and the magnitude and rate of
change consistent with society's preferences.
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Cite this document
APA
E. Gerald Corrigan (2005, June 14). Regional President Speech. Speeches, Federal Reserve. https://whenthefedspeaks.com/doc/regional_speeche_20050615_e_gerald_corrigan
BibTeX
@misc{wtfs_regional_speeche_20050615_e_gerald_corrigan,
author = {E. Gerald Corrigan},
title = {Regional President Speech},
year = {2005},
month = {Jun},
howpublished = {Speeches, Federal Reserve},
url = {https://whenthefedspeaks.com/doc/regional_speeche_20050615_e_gerald_corrigan},
note = {Retrieved via When the Fed Speaks corpus}
}