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At the Federal Reserve Bank of Philadelphia, Philadelphia, Pennsylvania
September 4, 2001

The Evolving Financial and Payment System
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 U.S. 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 check-collection 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 U.S. 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.
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2001 Speeches

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