The full text on this page is automatically extracted from the file linked above and may contain errors and inconsistencies.
FEDERAL R ESER V E BANK OF DALLAS Station K, Dallas, T e x a s 7 5 2 2 2 Circular No. 84-89 August 29, 1984 TO: All depository institutions Reserve District ATTENTION: Chief Executive Officer SUBJECT: White Papers approved by Board of Governors of the Federal Reserve System — “The Federal Reserve in the Payment System" and "Standards Related to Priced Services Activities of the Federal Reserve Banks" SUItlARY: Recently, the Board of Governors of the Federal Reserve System approved the attached copies of two policy statements known as White Papers. "The Federal Reserve in the Payment System" sets forth the rationale for Federal Reserve participation in the payment mechanism and "Standards Related to Priced Services Activities of the Federal Reserve Banks" details standards for Reserve Bank personnel to follow to ensure that conflicts of interests between the System's priced service activities and its other responsibilities are avoided. ATTACHMENTS: Board's press release and White Papers MORE INFORMATION: Tony J. Salvaggio, Extension 6224 ADDITIONAL COPIES Public Affairs Department, Extension 6289 in the Eleventh Federal B a n k s and o th e rs are e n c o u ra g e d to use the f o l lo w in g i n c o m i n g W A T S n u m b e rs in c o n t a c t i n g th is Ba nk: 1-800-442-7140 (in tr a s ta te ) a n d 1-800-527-9200 (interstate ). F o r c a ll s p la c e d lo c a lly , p le a se use 651 p lu s th e e x te n s io n re fe rred to above. This publication was digitized and made available by the Federal Reserve Bank of Dallas' Historical Library (FedHistory@dal.frb.org) FEDERALRESERVEpressrelease For immediate release August 14, 1984 The Federal Reserve Board has approved the two attached policy papers regarding the Federal Reserve System's role in the nation's payment mechanism and the System's policies and procedures designed to carry out provisions of the Monetary Control Act respecting providing services to depository institutions. One paper, entitled "The Federal Reserve in the Payment System" sets forth the rationale for the Federal Reserve's participation in the payment mechanism, describes the System's procedures for evaluating Federal Reserve priced services to depository institu tions and states the System's objectives, including cost recovery, for the pricing of such services as directed by the Monetary Control Act. The other paper -- "Standards Related to Priced Services Activities of the Federal Reserve Banks" -- is concerned with System safeguards for avoiding any internal conflict of interest between the exercise of the Federal Reserve's responsibilities for the provision of priced services to depository institutions, and its other principal responsibilities in the fields of monetary policy, bank supervision and lending to depository institutions. The primary responsibility for assuring that the standards are applied is en trusted to the management of each Reserve Bank. The Board exercises oversight over standards for provision of priced services through review and approval at Board level of changes in the level of pricing and services, and through frequent on-site reviews by Board staff of Reserve Bank activities. In addition, the Board specified in approving its policy statement that the Board member serving as chairman of the Board's Federal Reserve Bank Activities Committee is responsible for overseeing investigation and responses to complaints in this area. Vice Chairman Martin is the current chairman of this committee and inquiries may be directed to his attention. The policy statements are attached. - Attachments. 0- August 14, 1984 THE FEDERAL RESERVE IN THE PAYMENT SYSTEM This paper defines the mission and role of the Federal Reserve in the payment to clarify payment all the system Federal payment in purpose and to encourage closer improving the business mechanism The objective of Reserve's in order participants facilitate system. the planning services. The users paper role in is the cooperation among payment of the paper system and also and to providers outlines of the procedure the Federal Reserve will use in reviewing its service offerings. In summary, providing payment the mission services is to of the Federal promote the Reserve integrity in and efficiency of the payment mechanism and to ensure the provision of payment services equitable basis. of payments, even more to Given all the size, this mission important depository is, institutions speed, and will than it was when and on an interdependencies likely continue the Federal to be, Reserve was established in 1913. I. Role of the Federal Reserve Background For 70 years, active involvement by the Federal Reserve in p ayments processing has bee n an integral part of the 2- - development responding of the in part nation's to financial the breakdown of system in the early 1900s, 1913. the Congress At that time system. the established Congress, check collection the Federal Reserve in envisioned that the Federal Reserve would p lay a dual role as an operator and a regulator of as the payment 1980, mechanism. reaffirmed its The Congress has, commitment to this dual recently role for as the Federal Reserve. The Federal payment system. Reserve has a wide ranging role in the Reserve Banks process about 35 percent of the checks written in this country and provide a nationwide network for the collection of normal check bonds, and bankers' items collection ineligible channels, acceptances. for processing such The as Federal in developing the Automated Clearing House provides a nationwide electronic ACH the Federal (Fedwire). securities The Reserve's Federal service for nationwide Reserve also nationwide Reserve network provides of net (ACH) settlement a a each day Finally, variety system book-entry transfer relationships, for Depository transfer operates the safekeeping and account system and now in payments wire States government and agency securities. coupons, Reserve assisted network. institutions transfer billions of dollars over matured through of United through its the Federal of clearing arrangements. This participatory role has well— contributing directly and served indirectly the to United States widespread - 3- public confidence in a payment system that is quick, efficient. The well-suited to industry. system Federal the This spread Reserve's structure country has over wide of banking differing the areas with role States is financial fractionalized different and banking types of savings institutions and credit payments organization holds United a h i ghly institutions— commercial banks, unions— having participatory sure, more needs. than No four one percent private of total deposits or offers deposit services in all regions. If and when generalized structural interstate banking are authorized, rationale payment for a Federal mechanism consideration as will it is Reserve today. such as the underlying public p o l ic y operational continue changes to be Then, as as presence in important now, the the a Federal Reserve can be expected to bring to payments markets an overall concern for efficiency, relating to safety and soundness, and equitable access. integrity, efficiency promotion Indeed, and of operating those considerations access to the payment mechanism will remain at the core of the Federal Reserve's role and responsibilities regarding the operation of the payment mechanism. Integrity of the Payment System A reliable payment system is crucial growth and stability of the nation. to the economic The smooth functioning of markets for v irtually every good and service is dependent upon 4- - the smooth functioning of banking and financial markets, which in turn is dependent upon the integrity of the nation's payment mechanism. of History tells a country's payment general economic us— all too vividly— that system can precipitate or crisis. The breakdown of intensify the to precipitate the creation System— is a case in point. a relatively I.D., Herstatt, payments More recently, German and the the financial consequent disruption in clearly demonstrated dramatic rippling effect, the uncertainty Bankhouse regarding temporarily caused States financial payment failures via the payment Reserve the 1974 failure of institution, United that 1907— which Federal through private clearing networks, substantial This small of a payment machinery in the United States during the panic of helped fragility system, system. can hav e a to financial institutions in all parts of the world. The value private concern of funds transferred is and ongoing p articipation p ayment mechanism enhances example, the transfer service institution institutions. large that is perceived as able adequately to ensure integrity and reliability of the system. direct so Federal could the The Federal Reserve's the final risk rapidly The current effort large dollar payment networks the operation of the integrity and reliability. Reserve's reduces be its in no irrevocable that failure transmitted to control to For Fedwire of one other intraday risk on is another example of a Federal - Reserve initiative, 5- in conjunction wit h the private sector, to enhance the integrity of the payment system. Efficiency of the Payment System Federal Reserve involvement in the payment system promotes efficiency for a variety of reasons. The Federal in seeking to stimulate payment mechanism. other Reserve has providers a public improvements of payment mechanism has the know-how to contribute to help ACH. that Federal promote involve Reserve appropriate for cooperation among introduction and Moreover, to develop implementation. it This is significant payment mechanism substantial involvement depository Because of in the payment mechanism, their advancements and resources, may that also require institutions implementation of be such as the particularly widespread (for MICR encoding example, of checks). Federal Reserve involvement as a neutral and trusted intermediary improve the to such advancements as well as particularly true in the case of advancements services in technology and procedures. its day-to-day operating presence ability in the efficiency of The Federal Reserve has worked closely with utilize advancements the interest motivation may facilitate the efficiency of efficiencies result from acceptance the payment the scope of participation in the payment mechanism. of innovations mechanism. the Federal that Additional Reserve's 6- - As Congress anticipated in the Monetary Control Act of 1980, competition b etween the Federal Reserve and other providers of payment services has resulted in a more efficient payment system. Both the Federal suppliers have b ee n prompted b y three years the to trim cost Reserve and other competition during of processing service the payments last and to improve the q uality of the services offered. It efficiency advances is recognized are in most that likely electronic to further come gains from technology. the These institutions impediment to electronic payments, the regardless conversion of however, of gains size the will of become available to all or paper-based is payment application more widespread as the new technology becomes depository in location. An payments significant to float advantage enjoyed b y some initiators of paper-based payments. To advantage and eliminate shift the part of this to electronic payments, past two including years checks locations. in checks the accelerated drawn on thus Federal the institutions are now being at collected spur Reserve has collection As a result of these efforts, daily h elp of the during checks, relatively remote more than $3 billion and pai d one day quicker than was the case previously. Provision of Payment Services to All Depository Institutions Federal Reserve payment depository institutions, services are available including smaller to all institutions in 7- - remote locations serve. Under services that the available other Monetary to providers Congrol depository might Act, in choose making institutions, not to payment the Federal Reserve is to give due regard to the provision of an adequate level of services nationwide. Since implementation of the Act, the Reserve Banks have opened services to nonmember banks, access mutual currently handle paper and Federal Reserve savings banks, savings and Furthermore, the Reserve loan associations and credit unions. Banks to electronic items that are destined for over 20,000 depository institutions. The Federal Reserve payment mechanism services also stands ready to to troubled depository provide institutions that other providers of payment services may not serve because of the risks involved. This helps of a depository institution not trigger to make its insolvency and can be resolved to ensure that the inability or process payments will that the institution's problems in an orderly fashion with minimum disruptive effects. Fiscal Agency Functions In addition to depository institutions, provides a variety of Treasury creation, and other the payment the Federal Reserve, services on behalf of government safekeeping, evidencing ownership of governmental payments. services and agencies. transfer of provided as fiscal agent, the United States These include book-entry the public debt and to the records the processing of 8- - To the extent that the facilities and expertise required to provide these services can be used to produce other similar services for depository efficiencies result. services are institutions, In addition, supplied to the paper and electronic payment Treasury and other agencies at lower costs than would be possible opportunities for the Federal production Reserve also government if there were no to offer these services to depository institutions. II. Criteria for Federal Reserve Services In offering payment services, satisfy Act: the cost in the long recovery run objective aggregate the Federal Reserve must of the revenues Monetary Control should match costs. The Federal Reserve is currently achieving this objective. In addition specified to the in the Monetary Control Act, adopted b y the Board of Governors stringent objective of operating and costs capital) aggregate for float each full service cost and in cost recovery objective the pricing 1980 recovery imputed line.— ^ added the more (including taxes Based principles on and more all return than on two years of experience with the provision of priced services, internal objective of cost recovery at each b een elaborated to provide that revenues must cover all operating costs, 1/ service for each float costs, this line has service line and certain See Appendix for details on calculation of costs and fees. - imputed costs such as the 9- cost of interest on short- and long-term debt as well as make some contribution to the pre-tax return on equity. Thus, each service line must be at least marginally "profitable" and all service lines combined must, the aggregate, PSAF. At transfer present, and service cover net lines objective. the float costs, collection, settlement, meeting and the this commercial this objective, Only costs, check are The all ACH cash secondary service securities the overall services, book-entry cost line after taking into account definitive and is wire securities recovery also meeting the planned safekeeping in and subsidy. noncash collection service line is not presently meeting this objective. Federal Reserve objectives are established in terms of cost recovery rather than targeted volume. Circumstances might materialize that could jeopardize the Federal Reserve's ability to meet include its cost changing institutions. be improved recovery technology to be simply objectives, more into cannot the appropriateness taking and Such responsive Federal of the expected to Reserve would continuing account to its to other depository market, meet provide of such developments can If it becomes clear, be circumstances consolidation If a service experiencing continue to be offered. service objectives. it however, cost the that the recovery reassess objectives, would the service including after the requirement of providing equitable access and an adequate level of services nationwide. For example, several Reserve Banks 10 - - have stopped offering the cash transportation where an adequate level of this service service in areas is otherwise provided b y the private sector. Failure result from an providers. Federal to meet aggressive Because Reserve the to give decision would have continuing cost recovery pricing Monetary policy due regard the service by corrected. service some In any event, that could objectives temporary would not be by the Federal there were clear public benefits comment course of action. Similarly, particular line giving due the factors, shortfall. that expected which way the a The that shortfall could be any decision to continue to provide a soliciting public orderly directs the public benefits of situation after service service if the revenue reasonably be made Act also to provide a service did not meet cost recovery objectives caused other to competitive justify Federal Reserve might also continue was of Control to be made whether to offer objectives -may Reserve and only regard have to these Board only in associated with such a to be the meet in circumstances any decision would to to withdraw from a undertaken transition in an problems associated w i t h the discontinuation of service offerings. The Federal Reserve's operational presence in the payment system can be expected to change as the payment system evolves. Technological developments are likely to be important influence, increased interstate but changes banking, also the can be creative the most expected efforts from of - individual depository 11 - institutions, participants in the payment system, the entry of new and developments in law and regulation accommodating these and other changes. As the Federal Reserve introduces major service enhancements in the future, new services all of or the following criteria must be met: (1) The Federal Reserve must expect to achieve recovery of costs over the long run. (2) The Federal Reserve must expect its provision of the service to yield a clear public benefit, including, for example, promoting the integrity of the payment mechanism, improving the effectiveness of financial markets, reducing the risk associated with payments and securities transfer services, improving the efficiency of the payment mechanism or reducing the use of real resources such as throuah the introduction of new technology. (3) The service should be one that other providers alone cannot be expected to provide with reasonable effectiveness, scope, and equity. For example, it may be necessary for the Federal Reserve to provide a payment mechanism service to ensure that an adequate level of the service is provided nationwide or to avoid undue delay in the development and implementation of the service. The Federal p osition carries with Reserve recognizes that it unique responsibilities, willingness to cooperate with other providers payment mechanism and fairness. analysis, underlying These a fundamental unique be viewed as its an extension responsibility soundness of, and improving, for of must, the preserving unique including a in improving the commitment responsibilities full to competitive in Federal the the payment system. the final Reserve's safety and - III. Possible Payment System Improvements The Federal payment mechanism. by 12- some depository Federal Reserve Reserve is In this regard, institutions introduce and offer new services system. In before such such cases, enhancements others improving in enhancements that will further and to the interest has b een expressed and major services all committed to improve study will services having could be the existing the payment be required offered for public comment or for implementation. Among other things, feasibility, particular regarding cost and such study will focus on technical benefits, initiative with the the payment mechanism, initiative with the three the compatibility Federal and criteria might independently best or be acting developed for new by jointly with are Reserve believes year or several warrant service Federal depository as was particular areas the service offerings that attention These Reserve institutions the case with MICR encoding of checks and the introduction of ACH. there mission in this paper. the and other providers of payment services, in mind, the the compatibility of and major service enhancements specified services Reserve's of the over W i t h this Federal the next two. Th e y include: Minimization of the costs and the time associated with the h a n dling and processing of return items. Initiatives in this area may entail certain short term efforts such as notification of the institution of first deposit of large dollar return items along the lines proposed by the Board in June 1984. Long term efforts m a y - 13- require the application of new and higher technology to return item processing as well as continued efforts to accelerate the collection of checks more generally. ° In part related to improvements in the return item process, efforts to speed up the collection of checks as well as eliminate some of the physical handling of paper b y applying electronic technology to the existing paper-based system. Some form of check truncation, for example, appears to be a logical step in the progression toward electronic payments. Book-entry service for selective and limited classes of securities not presently held in b ook-entry form, such as municipal securities, might offer attractive economies while improving security and the payment flow. The Federal Reserve could provide access to a number of institutions that might not have access to existing alternatives. Enhancements to existing electronic services, including improved electronic delivery and security of payments. * The payment * * * system will * continue to evolve, adopting new technologies and creating new risks and opportunities. Federal Reserve has an important role as a participant evolution. As opportunities services to within such, the improve Federal Reserve existing the framework of services will or satisfying The in that seek offer new its responsibilities to promote the integrity and efficiency of the payment system, nationwide, providing an adequate level of services and serving the long range interests of the economy. APPENDIX Methodology for Computing Federal Reserve Bank Costs and Fees In accordance with the Monetary Control Act, the Federal Reserve establishes prices for its payment services in order to recover costs and a private sector adjustment factor (PSAF). The PSAF is an allowance for the taxes that would have been paid and the return on capital that would have been provided had the Federal Reserve's priced services been furnished by a private sector firm. Costs for providing services are derived from the Federal Reserve's Planning and Control System (PACS). PACS is the uniform financial accounting system Reserve Banks use for determining the full costs of fulfilling their four basic areas of responsibility: Monetary Policy, Supervision and Regula tion, Treasury, and Financial Institutions and the Public (the latter includes both priced and non priced services). The system was developed in the mid- 1970's to serve as a cost accounting system, similar to systems used in the private sector, and also to serve as a vehicle for evaluating the costeffectiveness and relative efficiency of Reserve Banks. PACS provides the Federal Reserve with an important management tool for budgeting and expense control by ensuring that similar expenditures are recorded by Reserve Banks in the same way and that all Reserve Banks post and report operating expenses under a set of common and uniform definitions. Like most expense accounting systems used in the private sector, expenses under PACS are classified by type or "object" of expense, such as salaries, supplies, equipment and travel, and the reason or "output" - 2- to which the expense is related, such as fiscal service to the Treasury or the provision of check collection services to depositing institutions. Classification of expenses by type enables the Federal Reserve to collect necessary information for external and internal financial reporting and control purposes. Classification of expenses by reason or output enables Federal Reserve management to analyze the overall costs of Reserve Bank operations in terms of on-going service responsibilities, the programs instituted to fulfill these service responsibilities, and the basic activities or processes included in the provision of each service. Within each area of responsibility ("service line") there are sub sidiary "services". The "Services to Financial Institutions and the Public" service line, for example, encompasses priced services such as commercial check, electronic funds transfer, securities and non-cash collection. Within each of these subsidiary services, PACS identifies specific "activities" which reflect the basic operations or processes within the services. PACS classifies all costs into three categories: direct costs, support costs and overhead costs. Direct costs are those costs directly attributable to a given service. Support costs are those costs, such as computer programming and building maintenance that, although not directly used in priced service operations, are required to support such activities. All support costs are fully charged to the benefiting activities on a usage basis. Overhead costs represent all remaining Federal Reserve costs that cannot be charged directly to an output service on a usage basis. Examples of overhead functions include personnel, protection and budget control. - 3- Overhead costs are allocated to benefiting services based upon formulas that reflect relative usage. Each year, all Federal Reserve fees are reviewed and revised, if necessary. the year. The annual review takes place during the third quarter of Each Reserve Bank forecasts its costs and volumes for each priced service for the upcoming year. Included in the cost estimate is all direct, support, overhead, and float costs that are to be allocated to each priced service line. The cost and volume estimates are based on a combination of historical experiences and projections. At the same time, the Federal Reserve calculates a proposed PSAF for the year. Services that have Systemwide uniform prices are based upon the aggregate cost and volume estimates of the 12 Reserve Banks. Fees for other priced services (check, safekeeping, etc.) are based upon cost and volume estimates of the individual Reserve Banks. The proposed fees of the Reserve Banks are reviewed by the System's Pricing Policy Committee and the staff of the Board of Governors. The purpose of the review is to ensure that the cost and volume estimates are reasonable, the PSAF calculation is consistent with System guidelines, and that proposed prices meet the cost recovery policies of the Board of Governors. the Board of Governors reviews the proposed prices and PSAF. Finally, August 14, 1984 STANDARDS RELATED TO PRICED SERVICE ACTIVITIES OF THE FEDERAL RESERVE BANKS I. Background Since 1913, the Federal Reserve has performed role as b oth an operator in and a regulator of a dual the nation's payment mechanism. Over the last 70 years— and as recently as 1980— Congress reaffirmed Reserve. has this role The Monetary Control Act of of 1980 the (MCA) Federal has the Federal Reserve's role b y requiring the Federal provide its equitable services basis, to taking all depository into account expanded Reserve institutions the need to on ensure to an an adequate level of services nationwide. The Federal Reserve has exercised care to avoid actual or apparent conflict b etween its role as a provider of services and its role the Federal promote Reserve the mechanism. as a regulator, As depository basis. manner Federal that careful integrity exercises care all is an and Reserve services. Moreover, safeguards that of that institutions on ensure this, an actions to there are that and lender. that of the its the Further, actions payment Federal Reserve it provides payment services fairness ensure to efficiency extension to ensure ensures supervisor equitable are also other and in place external these impartial implemented providers objectives are to of and in a payment internal achieved. - Externally, directly the and safeguards through statutory controls. provided b y all include the General congressional Accounting oversight, Office, and An additional level of external review is the public significant 2- Board include oversight b y through the opportunity proposals. the Board The of to comment on internal Governors safeguards and Reserve Bank boards of directors through various means, including use of the Board examiners and auditors. the Federal conduct of Reserve Reserve itself Bank internal imposes restrictions its employees--restrictions intended Finally, upon the to avoid even the appearance of impropriety. To paramount ensure in further providing that priced its public services interest under the role is MCA, the responsibility for following additional standards have been adopted. II. Standards A. Organization and Operations 1. No Reserve priced Bank services, President or responsible unless First Vice with acting in the President, for m o n et a r y policy, lending areas. policy personnel bank capacity will also of be supervision, or Priced service personnel will not make decisions affecting monetary supervision or lending matters. policy, bank Branch managers m ay administer p oli cy decisions Reserve Bank in the lending area but m ay not of a make policy decisions in this area. Federal Reserve institution lending in actions the functions institution will relative to monetary policy, involving be made a depository supervisory, a particular without or depository regard to whether that institution is a user of Reserve Bank services or is an alternative provider of such services. Except for the President, manager, or Reserve Bank bank persons Federal acting personnel supervision or Reserve personnel involved these capacities. in monetary policy, lending function may discuss the institution only where in branch involved priced responsibilities. First Vice President, services with necessary W ith the in priced to a depository carry exceptions services out their noted may above, discuss matters relating to monetary policy, bank supervision, or only lending with a depository the information discussed institution is general in nature where or is public. Reserve bank Bank personnel supervision or involved the lending in monetary policy, function may confidential information their duties to Reserve Bank priced services personnel only such where action obtained fulfills in an the provide course important of 4- - supervisory objective, p ayment mechanism Reserve Banks. provided on or In preserves protects such the integrity of the cases, assets of information a need-to-know basis and the the will be only w ith the approval of senior management. B. Business Practices 1. All activities incident to the provision of services will be conducted in a manner consistent with role and responsibilities the public that priced is fully of the Federal Reserve. 2. Federal Reserve services will be offered on a fair and equitable basis to all depository similar terms and conditions. be in accordance w ith institutions on The prices charged will the requirements of the MCA as implemented by policies of the Board of Governors. 3. Reserve Banks will provide full and accurate information regarding the provision of Federal Reserve services, operating including features, requirements, institutions to make to quality, enable prices and depository informed decisions. Comparisons of its services w ith those of other providers will .be fair and objective. 4. When introducing or revising will announce such changes that will ensure that services, Reserve Banks to the public communications in a manner reach all - interested depository 5- institutions in sufficient time to enable them to make appropriate adjustments. III. Internal Oversight The primary responsibility for assuring that the above standards are applied Reserve Bank. that these is entrusted Accordingly, standards are to clearly represented in Reserve oversight of business conduct Bank's internal audit function. Reserve Bank each maintains Bank Consistent with its overall each Reserve Bank's board of directors, each of Reserve Bank management will ensure policies, procedures and controls. responsibilities, the management is provided by principally through the The internal audit function of independence from operating management b y reporting directly to the Reserve Bank's board of directors. Oversight of Reserve Bank priced service activities is also carried out by the Board of Governors. This accomplished through review and approval at the Board price and priced service service level changes. activities are Furthermore, evaluated in is level of Reserve Bank conjunction with on-site reviews by the Board's operations review and financial examination ensures staffs. that Reserve Board Bank oversight activities through these means are consistent with the MCA and with Board policies with regard to priced services. addition, Board's the Board Federal member Reserve serving Bank as the Activities Chairman Committee of the is In - responsible for 6- investigating and responding to concerning actions of Reserve Bank personnel to be inconsistent with Currently, Vice capacity. Accordingly, the Chairman standards complaints that are presented Preston Martin alleged above. serves in inquiries concerning Reserve this Bank actions may be directed to Vice Chairman Martin's attention. The internal audit and Board examination focus on Reserve Bank compliance with policies, controls, service including standards activities. encompasses structure Audit activities and and staffing, allocation of costs, of and conduct functions financial procedures and related examination such as to priced attention also organizational accounting and information flows, activities reporting, and associated internal controls. IV. Conclusion It is the poli c y and practice of System to conduct maintain the effective Federal its affairs integrity -discharge Reserve Federal Reserve and credibility its p u blic of believes address questions in a manner that of potential to fulfill these the Federal that will essential serve to responsibilities. standards conflicts Reserve to the The effectively while permitting its public responsibilities in the the provision of services to the nation's depository institutions.