Roger W Ferguson, Jr: The evolving financial and payment system
Remarks by Mr Roger W Ferguson, Jr, Vice Chairman of the Board of Governors of the US Federal
Reserve System, at the Federal Reserve Bank of Philadelphia, on 4 September 2001.
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I am pleased to be with you this evening and I would like to thank Tony Santomero for inviting me to
share a few thoughts with you about my recent work on financial sector consolidation and payment
system issues. Changes in technology, business needs, and regulation are affecting both of these
areas in important ways, and in some cases with highly visible results.
Deregulation of the US financial industry over the past ten years has helped to support dynamic and
creative financial markets. During the same time, accelerating changes in technology have created
new financial products and services as well as whole new ways of conducting financial business.
Outside the United States, similar forces have been at work, although the details depend on the
particular country or region. One of the largest recent changes has been the introduction of the euro
and its effects on the structure of financial markets in Europe. The next step in this process will be
taken next January when euro notes and coins will be put into circulation. In both the United States
and overseas, there also have been a significant number of bank mergers, some of them very large,
arising from these changing financial industry dynamics.
G-10 study of financial sector consolidation
Against this background of ongoing change in financial structure, the finance ministers and central
bank governors of the Group of Ten countries commissioned a major study of the possible effects of
financial consolidation. I was asked to oversee that study, whose key findings were published last
January and covered thirteen developed countries, including the United States. The study
documented the high levels of mergers and acquisitions among financial firms during the 1990s,
including a noticeable acceleration during the last three years of the decade. Most of the consolidation
was within countries and within segments of the financial sector. Cross-border or cross-sector
consolidations have so far been less frequent.
The data we collected suggested a number of conclusions. For example, financial consolidation has
concentrated payment and settlement flows among fewer parties. The risk implications of this
consolidation deserve close monitoring. In addition, the study found that although consolidation has
some potential to improve the operating efficiency of the combined financial institutions and has done
so in some cases, the overall evidence in favor of efficiency gains is weak. The study also found that
the effects of consolidation on competition and credit flows are very case specific and depend on the
nature of the markets for specific products and services.
While the study found that financial consolidation has not significantly affected either the conduct or
the effectiveness of monetary policy, we also concluded that central banks should remain alert to how
future consolidation may affect the competitiveness of the markets that are most important to
monetary policy. Central banks should also monitor potential future changes in the transmission
mechanisms for monetary policy.
Finally, the study concluded that existing policies appear adequate to address risks to the individual
firm and systemic risks now and over the intermediate term. Looking ahead, however, the study
identified a number of areas that deserve careful attention by policymakers. For example, enhanced
contingency planning could reduce systemic risk should a large and complex financial institution
become seriously distressed. Because no institution is too big to fail, I believe that regulators should
also develop a clearer understanding of key factors such as the administration of bankruptcy laws and
conventions across borders; the coordination of supervisory policies within and across borders; the
treatment of over-the-counter derivatives, foreign exchange, and other financial market activities in
distress situations; the roles and responsibilities of managers and boards of directors; and the
administration of the lender-of-last resort function. Our study also helped clarify the need for
international attention to contingency planning. In general, both crisis prevention and crisis
management would improve with additional communication and cooperation among financial
supervisors domestically and among central banks, finance ministries, and other financial supervisors
internationally.
Evolution of the payment system and strategies for further change
Payment systems, especially retail payment systems, have also been evolving over time, although not
dramatically. Unlike the households of ten or twenty years ago, however, households now frequently
receive wages and salaries electronically and buy goods and services using credit or debit cards. The
past few years have seen varied levels of development, both here and abroad, of new card-based and
software-based payment instruments and systems, such as electronic money and Internet payment
systems. Yet cash and checks remain the mainstays of retail commerce in the United States; this is a
testament to the broad convenience of these instruments, developed over a long period, and the
public's confidence in them.
But the payment system is continuing to evolve. At some point, it is likely that the use of checks will
start to decline, as it has in several other developed countries. One factor involved in this change is
the increasing use of debit cards as a substitute for some check payments, especially those made at a
merchant's point of sale, or POS. In some countries, such as Canada and the United Kingdom, this
substitution has progressed substantially, and consumers now use debit cards widely. In the United
States, we have seen the use of debit cards grow strongly over the past few years, fueled by the use
of signature-based cards developed by the credit card networks.
Another recent development is the increasing adoption of programs to "convert" or "electronify" checks
at the point of sale. These programs typically use a check, or information from a check, to generate an
electronic payment from the consumer to the merchant that is cleared through the automated
clearinghouse (ACH) or electronic funds transfer (EFT) networks. In a sense, these programs turn a
check into a disposable debit card. This analogy raises the question of what we can learn from the use
of checks to initiate electronic payments and whether these programs are simply a transition stage to a
more extensive electronic payment system. I believe these programs continue to deserve monitoring
as we go forward.
This evening I would also like to mention an old debate about the merits of check truncation, a debate
that goes back at least to the late 1960s and early 1970s, when many observers of the payment
system first began predicting the quick rise of a cashless and checkless society. In the past, the
banking industry and the Federal Reserve have studied suggestions for the widespread truncation of
checks at the bank of first deposit or at an intermediary bank to reduce the costs of the
checkcollection system. The results of these studies have been sensitive to assumptions about technology,
transition costs, implementation timing, discount rates, and other factors. In addition, assumptions
about the storage and retrieval of truncated checks or their images can affect an analysis. Most
fundamentally, the degree to which banks and the public accept truncation and the associated
electronic presentment of checks significantly affects the banking industry's ability to achieve
economies of scale and standardization throughout a truncation and electronic collection system.
Historically, sensitivity to these key assumptions has injected uncertainty into the business case for
check truncation and electronic collection. As a result, the banking industry has faced difficult
decisions about whether to invest in the truncation of checks or to invest in fully electronic payment
technologies, such as the ACH or card networks, while encouraging their customers to initiate
electronic payments from the beginning of a payment process. To date, the industry has done some of
both, with business strategies varying across banking organizations.
With recent declines in technology costs and increasing consumer acceptance of check truncation,
however, some banks have accelerated their efforts to truncate checks. The Federal Reserve Banks
now electronically present more than 20 percent of the checks they collect, of which one in four are
also truncated at the Fed. Several banks, including the Federal Reserve Banks, are also building data
archives in which to store digital images of checks to replace microfilm technologies and to provide
mechanisms to process images of truncated checks. Some commercial banks also believe that
greater automation of check data within their organizations, along with other customer information, can
significantly speed and improve the overall quality of their customer service. These banks tend to see
check truncation, electronic presentment, and check imaging as parts of a larger business strategy
linked to automation, not simply as stand-alone, back-office operations. Other banks tend to analyze
these automation steps more narrowly as tools to reduce back-office costs, and they remain
somewhat skeptical about the business case for truncation and related activities.
Payments System Development Committee
I would like to turn now to the Payments System Development Committee, which is working with the
private sector to better understand the issues arising from the evolution of the retail payment system.
The committee, which I co-chair with Cathy Minehan, President of the Boston Fed, was established by
the Federal Reserve Board in mid-1999 to (a) identify strategies for enhancing the long-term efficiency
of the retail payment system, (b) identify barriers to innovation and work to reduce or eliminate those
barriers when doing so is in the public interest, (c) monitor market developments, and (d) conduct
workshops and forums for focused discussions about the payment system with the private sector.
One of the committee's key projects during the past year has involved working with the public and
private sector on a long-run strategy for facilitating the market adoption of check truncation and greater
electronic check processing when this makes economic sense. The basic idea is that if a bank
believes that truncating some or all of the checks it receives makes business sense, it should be able
to do so without worrying about demands by other parties that the original check must be located and
presented. When such demands are made, a legally sanctioned paper copy of the original could be
provided in place of the original. A federal statute would provide the legal framework within which such
a paper copy - or substitute check - would be produced, along with safeguards against paying the
same check twice and other potential problems. The market theory of this approach is that by
facilitating the use of substitute paper checks when a paper check is preferred, larger investments in
truncation and electronic presentment may become economical over the longer term. In short, through
this approach, the demand of some for paper checks will carry less weight in the business decisions of
the many. Moreover, those who want a paper check will be able to obtain it with a minimum of
inconvenience. With more electronic infrastructure, however, check collections potentially will be faster
and cheaper, and customer-banking platforms within commercial banks may become more
technologically integrated. In the end, the goals are to reduce the social cost of the payment system
and to improve the technical foundation for providing financial services.
The Payments System Development Committee also is working on various legal and regulatory
issues, standards, and the future of clearing and settlement. In the regulatory area, for example, the
committee has encouraged the Board's staff to revise the commentary to Regulation E, which
implements the Electronic Fund Transfer Act, to reduce residual barriers to electronic innovations.
Revisions last March helped clarify the legal status of the various "check conversion" projects that I
noted earlier.
In the standards area, we are closely following the work being done under the aegis of the American
National Standards Institute (ANSI) on standards that would support the use of substitute checks
within the context of both bilateral and multilateral industry efforts to pursue check truncation. In
addition, this past June, the committee held a one-day workshop on the implications of XML
(eXtensible Mark-up Language) for the payment system. This workshop, held at the Boston Fed,
involved a variety of representatives from both the private and public sectors. The workshop's major
purpose was to provide the committee with a number of different views on the significance of XML for
the payment system and the possibility of adopting a widely shared and flexible computer language for
exchanging electronic payment messages and related information. Those discussions and other
information suggest that XML is becoming increasingly important in the financial markets and that it
raises interesting possibilities for the future.
In the clearing and settlement area, the committee is discussing how new technology and business
needs will interact to affect the design and functions of clearing and settlement systems in the future.
Some have observed that in the long run, new technologies, along with the needs of e-business, will
lead to important changes in clearing and settlement systems. In addition, the use of new technologies
to conduct traditional payment system operations in more efficient and effective ways will also drive
change. Both banks and end-users of the payment system are now discussing many issues and ideas.
The committee has asked a group of staff to conduct further discussions with interested organizations
and bring back to the committee a broader view of the current debate in this area.
Finally, the committee is continuing to encourage survey research on the use of different payment
systems. The Federal Reserve's Retail Payment Office is currently sponsoring several surveys to
obtain more accurate data on both electronic and check payments being made in the United States. It
is particularly important that we have a better idea of how many checks are being written in order for
the banking industry and the public to understand better and plan for the evolution of the payment
system. The technical work of "cleaning the numbers" collected in the surveys is continuing, and we
hope to publish data from the survey later in the year.
Conclusion
In conclusion, I would like to emphasize that our financial system is continuing to evolve, as it must in
a dynamic and competitive market economy. Financial consolidation at the national level has occurred
relatively quickly, although much less so at the level of individual banking markets. The recent G-10
study did not find fundamental problems with developments to date. It did, however, outline some
practical steps the authorities can take to help better manage potential risk to the financial system and
outlined a number of areas that should be monitored and analyzed further over the longer term.
Overall, the US payment system continues to evolve slowly, but there have been steady changes and
a great deal of experimentation over the past few years. Although we are not likely to see paper
payment instruments disappear, electronic payment systems are being used more widely and
creatively than in the past. On-line banking and other services are giving bank customers new and
convenient mechanisms to initiate and receive electronic payments. However, simple ideas such as
electronic bill payment by consumers and businesses have turned out to be more of a challenge than
we imagined a few years ago.
In addition, as the market continues to experiment with new systems, the old themes of reliability,
security, privacy, and confidence need to be repeated often. Speaking as a member of the Payments
System Development Committee, I would also like to emphasize the willingness of the committee
members and the Fed staff to discuss with private-sector organizations their new ideas, insights, and
views about the future of the payment system. I have found that our discussions so far have all been
very productive in helping to broaden our thinking and to identify concrete steps that can be taken to
improve the payment system.
Thank you for your attention.