TESTIMONY OF MEHRSA BARADARAN Professor of Law University of California Irvine School of Law before the United States House of Representatives Committee on Financial Services Task Force on Financial Technology Chairman Lynch and Ranking Chair Emmer members of the Task Force on Financial Technology thank you for this opportunity to testify on “Inclusive Banking During a Pandemic Using FedAccounts and Digital Tools to Improve Delivery of Stimulus Payments ” As the United States enters a state of recession with unprecedented rates of unemployment savings accounts are being depleted expenses are rising and the future of household well-being appears uncertain Congress swiftly responded with the CARES Act to provide relief to families and businesses impacted by the virus A chief goal of this bill was to put money directly into people’s hands through increased benefits and direct stimulus payments Yet the dispersal of these funds has revealed deeprooted problems with the US payments system that have made it difficult for some of the Americans most in need to access stimulus funds Many Americans have had to wait long hours in ATM lines pay fees to alternative service providers or wait weeks or months to receive their stimulus funds 1 Up to 70 million Americans will encounter delays or problems in receiving their payments 2 For those without a bank account the wait can be as long as five months 3 The massive scale of this crisis will mix with the financial precarity of many Americans and will likely lead them into the open arms of high-cost checkcashers payday lenders title lenders pawn shops and other high-interest lenders Though this recession is likely to make these problems more acute the gaps in our exclusionary payments system are not new There are practical solutions to these problems that can quickly and effectively achieve financial inclusion and democratize the United States financial system I urge Congress to authorize basic checking accounts at the United States Postal Service in partnership with the Federal Reserve Payments System In order to cross the cash-to-digital divide unbanked and underbanked individuals need an account with physical locations Adopting digital accounts without providing access points for communities already excluded from the banking system would further exacerbate longstanding inequalities in access I The Problem Banks Do Not Serve Every Customer A quarter 25% of Americans are unbanked or underbanked 4 These low-income families spend about 10% of their total income in fees to alternative financial service providers just to use their money 5 Being underbanked is expensive and time-consuming as each financial transaction 1 involves fees and hurdles 6 The unbanked must spend time and money to send and receive money cash checks use debit cards and otherwise engage in commercial activities that are routine and nearly free for most Americans Only chartered banks and their customers can access the payments systems built maintained and overseen by the Federal Reserve 7 Yet banks are not mandated to offer these services to all people Banks have abandoned certain low-profit communities and customers Over the last several decades deregulation heightened market competition and the subprime crisis has led to wave after wave of bank mergers and a conglomerated banking industry Industry consolidation has left many communities especially in lower income zip codes without access to a bank 8 In fact rural America has lost over half of its banks in the last few decades with 1 in 8 communities designated as a banking desert 9 Due to industry consolidation 93 percent of the 1 800 bank branches that have closed since late 2008 were in postal codes where the household income is below the national median 10 In these banking deserts it is not uncommon that the only ATM in the entire area is at a gas station with fees up to $7 50 per transaction 11 Research shows that when banks leave a community businesses lose 20% of their revenue 12 Based on the current economic pressures on small banks and businesses more banks will likely have to shut their doors leaving small businesses in even more dire conditions This is a particularly acute problem for Minority-owned businesses who are particularly vulnerable to failure in challenging economic conditions 13 Even in zip codes where banks are physically available there remain many barriers for lowincome Americans The FDIC survey of the unbanked and underbanked showed that over one third of respondents did not trust banks with distrust increasing over time Banks charge excessive and onerous overdraft fees and excess activity fees—fees that are lucrative for banks and disastrous for low-income consumers 14 Banks no longer offer small loans and though some promise “free checking ” there are hidden fees and requirements that repel most small balance customers Most banks require balances of $1 500 to avoid fees on their basic accounts and small accounts are not profitable for banks so they avoid them—either by leaving low income areas or repelling low income customers through fees 15These fees borne primarily by LMI bank customers has become a profitable business with some large regional banks reporting that fees account for 40% of their income Together consumers paid $17 billion in overdraft fees in 2015 according to the Center for Responsible Lending 16 Faced with seemingly random and punitive fees low-income customers have taken their business to the fringe banking sector 17 Without bank accounts many Americans do not have a safe and accessible means for saving their money 18 More than 40% of Americans do not have even $500 in savings and would need to borrow if they had a shortfall—over 60% would need to borrow $1000 if they faced a financial emergency 19 Many Americans do not save because they do not earn enough even while working full time but even if they have money to save most accounts are not accessible to those with small savings 20 Cash savings are vulnerable to theft and loss 21 Research abroad has demonstrated that increased access to a savings account enhances economic welfare and other important outcomes 22 2 Having a safe low-cost and easy savings account could lead to more savings which could diminish the need for payday loans when families hit a snag 23 When individuals can dip into savings they are less likely to need payday loans Another important way that banks are not meeting the needs of low-income Americans is the delay in making funds available to customers Payments clearing—the time between when a check is deposited and when the funds can be withdrawn as cash—can take three to five business days For families who do not have a buffer of wealth and need to spend their paychecks for food or rent this delay is costly and onerous In order to avoid this time gap families often resort to checkcashers or payday lenders Estimates show that $89 billion is spent each year by the unbanked on financial fees and services including payday lenders check cashers pre-paid cards and other services 24 II The Federal Reserve Has a Mandate to Make Services Equitable The Federal Reserve payments system has proved secure private and safe and is among the most reliable in the world—but it is exclusionary Congress established the Federal Reserve in 1913 to increase the integrity efficiency and equity of US payments The Federal Reserve states that it has “a public-interest motivation in seeking to stimulate improvements in the efficiency of the payments system ”25 This according to their own mission requires it “to provide equitable access and an adequate level of services nationwide ”26 Indeed achieving this mission today is essential to helping many vulnerable Americans access much-needed funds during the current recession The Federal Reserve has only offered its payments system to banks with the implicit understanding that banks would provide these services to customers which they have not done This is a problem that can and must be fixed through policy rather than outsourced to technology or banking corporations to solve In order to achieve this mission the Federal Reserve must open up its payments system to all Americans If the Federal Reserve falters in its mission it falls in Congress’s purview to enforce it To the extent that this system is exclusionary it is up to our democratically elected representatives to update this mission and mandate that the Fed promote efficiency and financial inclusion to the benefit of more Americans Money itself is a public good and its creation supply and stability is a function of the US Treasury in coordination with the Federal Reserve 27 Every American not only deserves the right to participate in the economy but also to participate democratically in the federally supported payments system Financial technology companies “fintechs” and blockchain providers have promised that alternative technologies and services can lead to financial inclusion 28 Fintechs which are distinct from traditional banks provide technology-centered products and services directly to consumers Unlike traditional banks fintechs do not have access to the Fed’s payments system 29 They must partner with a U S chartered bank in order to offer payments services As required by anti-money laundering and anti-terrorism laws passed by Congress banks must ensure accurate identification of 3 their customers Allowing these private companies access to these essential payments systems without the oversight under which banks operate would put Congress’s interests in security and crime prevention in danger 30 These companies offer customers greater convenience and easy to use apps but their ability to achieve financial inclusion is limited due to their lack of a large physical footprint This is the critical missing step into widescale fintech or digital account use For communities without bank branches or for customers who are unbanked or underbanked the many fintech options including FedAccounts and digital wallets will not be able to overcome access issues if they are not linked with a place where cash can be deposited or withdrawn Moreover many communities do not have the technology yet to be able to move all of their financial transactions to mobile or internet accounts Many LMI individuals and communities with estimates between 20 to 40 million Americans do not have broadband internet services and many other users prefer cash or a simple debit card for transactions 31 Most LMI communities still operate at least some portion of their financial activities in cash and the majority of Americans with an income of less than $50 000 use a debit card as their preferred payment method 32 A physical location with simple ATM and debit card capabilities would help many Americans avoid the high cost alternative service providers Those who are unbanked need a way to cross the cash digital divide so they can engage in commerce III The Solution Digital Accounts at the Post Office A simple solution to this problem is for the postal service to offer a simple checking account with online capacities to all communities 33 The post office can provide the physical services necessary for the unbanked and underbanked to access FedAccounts digital wallets and other fintech services As America’s oldest instrument of democracy in action the Post Office can offer an essential service to every community This is not a new or radical idea The United States Postal Service USPS operated a savings bank for much of its history and the majority of postal services worldwide offer banking services Postal banking has been operational in many Western countries since the 1800s and currently fifty-one countries have postal banking as their primary method of financial inclusion—only 6% of postal carriers worldwide do not offer banking services It is estimated that postal banking has banked over 1 billion people worldwide 34 There are a variety of models worldwide—some focused on the poor and others that offer postal banking services to the entire population In fact the United States is one of the only developed countries in the world without a postal banking network Though we do not need to look abroad for a justification or even a model for postal banking when we can refer to America’s own rich history of postal banking The post office can deliver the physical branches ATMs and checking account services in partnership with the Federal Reserve that would provide the same access that it provides currently to banks The funds would be placed in the Fed’s reserve account which is the most secure depository in the world Many individuals and communities need a bridge toward the digital cash economy They need a point of physical contact so that people who need to withdraw cash or deposit their wages into an account and the Post Office is ideally suited to help with the transition 4 toward the digital economy In fact in communities without banking services many are already using the post office for simple financial transactions Financial journalist Kevin Wack reports that in a rural town that lost its bank one hotel proprietor “will walk over to the post office buy a single stamp and request a check back ” which is “cheaper than patronizing either of the town’s two ATMs ” An electricity cooperative in town uses the post office for their business accounts Rather than keeping a lot of currency on hand or embarking on long drives to the nearest bank an employee goes to the post office several days each week and buys a money order ‘Thankfully the post office is the unofficial bank ’ the cooperative’s CEO Steven Lunt said ”35 These customers and businesses need a way of converting cash to digital accounts and vice versa This is a crucial need that fintech providers are not able to meet in many areas Once customers have a digital account they can use fintech services for their transactional needs The Post Office has the largest physical footprint of any other institution with over 30 000 branches and over 160 million delivery points nationwide making it the most ideally suited institution to help LMI zip codes and rural communities cross the cash digital divide 36 Professors Terri Friedline and Mathieu Despard created a database and five research reports concerning US households’ access to financial services in which they determined that “37% of all zip codes in the US lack either a bank or credit union ” Further almost 90% of these banking deserts were in rural areas ” The concluded “the good news is that the density of post offices in these deserts is 1 11 per 1 000 people compared to only 0 27 in non-deserts This means that post offices are abundantly located in places where financial services are lacking ” It is these areas that have suffered the most from the trends toward acute inequality It is also in these regions where check cashers and payday lenders congregate Because the Post Office never left communities deserted by banks and other businesses it is not only available in all the regions forsaken by banks it has developed an ongoing relationship of trust within these communities Among the unbanked and underbanked many do not use banks because of a lack of trust Meanwhile a recent survey of the “Most Trusted Brands” in the United States the USPS was ranked number one—with the most survey respondents stating that it was the institution that they most trusted “to do what is right ”37 No banks were on the list of the top 25 companies The Postal Act of 1792 passed by Congress and signed into law by President George Washington gave the USPS a mandate to honor the privacy of citizens and to offer services to all communities For over 200 years the USPS has maintained its public-serving mission by offering equitable services to all I would urge Congress to continue their support of this foundational American institution by allowing it to help democratize the financial system The Post Offices could offer banking services across the country at a much lower cost than banks alternative service providers and even fintech because 1 they can use natural economies of scale and scope to lower the costs of the products 2 their existing infrastructure significantly reduces overhead costs and 3 they do not have profit-demanding shareholders and would be able to offer products at cost 38 Both postal banking and FedAccounts could be designed to create 5 revenue for the post office and the Federal Reserve while offering lower cost services to the unbanked and underbanked 39 In addition to physical branches and FedAccounts a Realtime payments could help eliminate unnecessary delays in processing 40 The technology is already available to modernize all of these issues that present obstacles for many Americans 41 Postal savings accounts have the potential to become an accessible and inclusive account for Americans left out of the banking system Many customers already operate a provisional savings account by purchasing money orders at the post office 42 Even having a few hundred dollars stored away can make a significant difference to a moderate-income family who may face an emergency in their lives It is difficult to measure how many people are not saving in banks because of financial and cultural barriers of entry but it is possible that just as in the past funds would pour into the postal banks from under proverbial mattresses in prepaid cards or otherwise wired abroad Just as our postal banks did successfully for half a century lowering barriers of access to low-cost savings accounts can greatly benefit a population living without any financial cushion IV Conclusion In order to meaningfully participate in the economy the excluded unbanked and communities living in banking deserts need access to the safe and subsidized payments system operated by the Federal Reserve Justice Louis Brandeis believed banking to be among the industries that might be considered a public utility because as he explained “deposit banking should be recognized as one of the businesses ‘affected with a public interest ’”43 Achieving an equitable financial system requires that the payments system operated by the Federal Reserve be opened to all The central bank payments system already resembles a public utility but it is currently only a public service open to banks who operate as an intermediary Opening the payments system to the unbanked and underbanked would not cause any disruptions to the financial market and would be a boon to low- and moderate-income families who are currently paying to use a public resource Postal banks would offer a free checking account with digital services that would enable the unbanked and underbanked to engage in simple financial transactions through the public payments system instead of high cost non-bank options It would also help the Federal Reserve achieve its Congressionally mandated mission of creating an equitable financial system 6 Matthew Haag To Reach a Single A T M a Line of Unemployed Stretches a Block N Y Times June 5 2020 https www nytimes com 2020 06 05 nyregion keybank-nyc-coronavirus html Receiving Your Unemployment Benefits by Direct Deposit or DUA Debit Card Mass gov 2020 https www mass gov guides receiving-yourunemployment-benefits-by-direct-deposit-or-dua-debit-card Lorie Konish Paper Stimulus Checks Could Be Delayed by up to 5 Months CNBC Apr 2 2020 https www cnbc com 2020 04 02 paper-stimulus-checkscould-be-delayed-by-up-to-5-months html Reports already abound of long wait times to submit unemployment claims either online or over the phone and even longer to have them approved Mallory Sofastaii Spike in Unemployment Claims Leads to Long Wait Times Delay in Benefits 2 ABC WMAR Baltimore Mar 26 2020 https www wmar2news com news coronavirus spike-in-unemployment-claims-leads-tolong-wait-times-delay-in-benefits Tony Romm Uber Drivers and Other Gig Economy Workers were Promised Unemployment Benefits It May Be a Long Wait Wash Post Apr 2 2020 https www washingtonpost com business 2020 04 02 uber-airbnb-lyft-unemployment-coronavirus Jerry Davich Waiting for Unemployment Insurance Benefits to Kick in ‘Just Hold Tight ’ Chi Trib Apr 3 2020 https www chicagotribune com suburbs post-tribune opinion ct-ptb-davich-applying-forunemployment-insurance-benefits-st-0406-20200403-rforrj7xdzakpan5dvt5x43iou-story html 2 Aaron Klein 70 Million People Can’t Afford to Wait for their Stimulus Funds to Come in a Paper Check Brookings Mar 31 2020 https www brookings edu opinions 70-million-people-cant-afford-to-wait-months-fortheir-stimulus-to-come-in-a-paper-check 3 Konish supra note 1 4 Fed Deposit Ins Corpo 2017 FDIC National Survey of Unbanked and Underbanked Households 2017 https www fdic gov householdsurvey 2017 2017report pdf Erin Barry 25% of US Households are Either Unbanked or Underbanked CNBC Mar 9 2019 https www cnbc com 2019 03 08 25percent-of-ushouseholds-are-either-unbanked-or-underbanked html 5 U S Postal Service Providing Non-Bank Financial Services for the Underserved 2014 https www uspsoig gov sites default files document-library-files 2015 rarc-wp-14-007_0 pdf 6 See Mehrsa Baradaran How the Other Half Banks Exclusion Exploitation and the Threat to Democracy Harvard University Press Oct 2015 7 Structure of the Federal Reserve System Board Governors Fed Res Mar 3 2017 https www federalreserve gov aboutthefed structure-federal-reserve-system htm 8 NCRC Research Banking Deserts in America National Community Reinvestment Coalition June 2017 http maps ncrc org bankdeserts index html Frank Bass Dakin Campbell Study Finds Latest Bank Branch Closing Strike Hardest in Poor Neighborhoods Bloomberg News May 2 2013 https www stltoday com business local study-finds-latest-bank-branch-closings-strike-hardest-inpoor article_b33a4103-280f-5b3c-9754-3086de4b0070 html Hous Assistance Council The Community Reinvestment Act and Mortgage Lending in Rural Communities 22 Jan 2015 http www ruralhome org storage documents publications rrreports rrr-cra-in-rural-america pdf 9 Randal K Quarles Chairman for Supervision Bd of Governors of the Fed Reserve Sys Trends in Urban and Rural Community Banks fig 1 Oct 4 2018 https www federalreserve gov newsevents speech quarles20181004a htm Hous Assistance Council supra note 8 10 Bass Campbell supra note 8 However as branches were closing in poorer neighborhoods banks “continued to expand in wealthier ones despite decades of government regulations requiring financial institutions to meet the credit needs of poor and middle-class neighborhoods ” Nelson D Schwartz Bank Closings Tilt Towards Poor Areas N Y Times Feb 12 2011 https www nytimes com 2011 02 23 business 23banks html 11 Janell Ross A Town With No Bank How Itta Benna Mississippi Became a Banking Desert NBC News June 15 2019 https www nbcnews com news nbcblk how-itta-bena-mississippi-became-banking-desertn1017686 12 Kevin Wack When a Small Town Loses its Only Bank Am Banker Feb 2 2020 https www americanbanker com news when-a-small-town-loses-its-only-bank 1 7 See Sifan Liu Joseph Parilla Businesses Owned by Women and Minorities Have Grown Will COVID-19 Undo That Brookings April 14 2020 https www brookings edu research businesses-owned-by-women-andminorities-have-grown-will-covid-19-undo-that see also Ron Jarmin et al Owner Characteristics and Firm Performance During the Great Recession CES September 2014 https www2 census gov ces wp 2014 CESWP-14-36 pdf See Also Mehrsa Baradaran The Color of Money Black Banks and the Racial Wealth Gap Harvard University Press 2017 14 Spencer Tierney Overdraft Fees Compare What Banks Charge NerdWallet Sept 6 2019 https www nerdwallet com blog banking overdraft-fees-what-banks-charge Jessica Dickler Bank overdraft Fees Could Jump if Consumer Watchdog Eases Rule CNBC June 26 2019 https www cnbc com 2019 06 25 bank-overdraft-fees-could-jump-if-consumer-watchdog-easesrule html Peter Smith Report FDIC Data Shows that Banks Collected $11 45 Billion in Overdraft Fees in 2017 Ctr For Responsible Lending Aug 7 2018 https www responsiblelending org media report-fdic-datashows-banks-collected-1145-billion-overdraft-fees-2017 Peter Smith Unfair Market The State of High-Cost Overdraft Practices in 2017 Ctr For Responsible Lending Aug 7 2108 https www responsiblelending org research-publication unfair-market-state-high-cost-overdraft-practices2017 15 Lisa J Servon The High Cost for the Poor of Using a Bank New Yorker Oct 9 2013 https www newyorker com business currency the-high-cost-for-the-poor-of-using-a-bank Abby Vesoulis Millions of Americans Can’t Afford a Checking Account The Post Office Could Fix That Time Aug 7 2018 https time com 5351706 postal-banking-kirsten-gillibrand Gov’t Accountability Office Community Reinvestment Act Options for Treasury to Consider to Encourage Services and Small-Dollar Loans When Reviewing Framework 2018 https www gao gov products GAO-18-244 16 Smith Report supra note 14 17 The rise of fringe banking check-cashing and payday lending was a direct result of the decline of community banks See Baradaran How the Other Half Banks supra note 6 18 Pew Charitable Trs Drowning in Debt A Health Impact Assessment of How Payday Loan Reforms Improve the Health of Minnesota’s Most Vulnerable 2016 https www pewtrusts org media assets external-sites health-impact-project hip-2016-payday-lending-report pdf https perma cc S7V6-VBZN 19 Bd of Governors of the Fed Reserve Sys Report on the Economic Well-Being of U S Households in 2017 - May 2018 https www federalreserve gov publications 2018-economic-well-being-of-ushouseholds-in-2017-dealing-with-unexpected-expenses htm 20 Sarah Holder Why Cleveland Wants to Bring Back Postal Banking CityLab June 4 2019 https www citylab com equity 2019 06 cleveland-post-office-banking-cash-check-predatorylending 590557 Derek Thompson Why Don’t Americans Save More Money The Atlantic Apr 19 2016 https www theatlantic com business archive 2016 04 why-dont-americans-save-money 478929 21 Holder supra note 20 Thompson supra note 20 22 Dean Karlan et al Impact of Savings Groups on the Lives of the Poor 114 Proc of the Nat’l Acad of Sci of the U S 3079 2017 23 Id 24 See Mehrsa Baradaran Postal Banking's Public Benefits 3 Am Aff J 18 23 2018 25 Federal Reserve’s Key Policies for the Provision of Financial Services Board Fed Res System Nov 20 2008 https www federalreserve gov paymentsystems pfs_frpaysys htm 26 Id 27 Morgan Ricks John Crawford Lev Menand FedAccounts Digital Dollars 89 Geo Wash L Rev forthcoming 2020 https ssrn com abstract 3192162 James Tobin The Case for Preserving Regulatory Distinctions in RESTRUCTURING THE FINANCIAL SYSTEM 167 172 1987 “I think the government should make available to the public a medium with the convenience of deposits and the safety of currency essentially currency on deposit transferable in any amount by check or other order … The Federal Reserve Banks themselves could offer such deposits ” see also Kenneth J Arrow The Organization of Economic Activity Issues Pertinent to the Choice of Market versus Non-market Allocations in ANALYSIS AND EVALUATION OF PUBLIC EXPENDITURES THE PPP SYSTEM 48 J Econ Comm of Cong 1969 13 8 “The creation of money is in many respects an example of a public good ” CHARLES P KINDLEBERGER ROBERT Z ALIBER MANIAS PANICS AND CRASHES A HISTORY OF FINANCIAL CRISES 19 6th ed 2011 “Money is a public good ” John Cochrane Remarks at the Federal Reserve Bank of Minneapolis May 16 2016 “There’s a few things that government has a natural monopoly in national defense courts property rights and I would say money ” 28 William Magnusson Regulating Fintech 71 Vand L Rev 1167 1174 2018 Mehrsa Baradaran Rethinking Financial Inclusion Designing an Equitable Financial System with Public Policy https rooseveltinstitute org rethinking-financial-inclusion-equitable-financial-system-public-policy 29 Odinet Christopher K Securitizing Digital Debts April 23 2020 Arizona State Law Journal Vol 52 2020 Available at SSRN https ssrn com abstract 3583688 30 31 U S C § 5311 et seq 2018 31 C F R § 1010 220 see also Bridget Mayer Briggs Ariel S Glasner The FinTech Revolution Complying with Anti-Money Laundering Laws to Avoid Regulatory Enforcement Action BlankRome Apr 2018 https www blankrome com publications fintech-revolution-complying-anti-moneylaundering-laws-avoid-reg 31 Linda Poon There Are Far More Americans Without Broadband Access than Previously Thought February 19 2020 https www citylab com equity 2020 02 internet-access-rural-broadband-digital-divide-map-fccdata 606424 32 TSYS U S Consumer Payment Study TSYS 2018 https www tsys com Assets TSYS downloads rs_2018-us-consumer-payment-study pdf 33 Mehrsa Baradaran It’s Time for Postal Banking 127 Harv L Rev F 165 2014 See MORGAN RICKS JOHN CRAWFORD LEV MENAND CENTRAL BANKING FOR ALL A PUBLIC OPTION FOR BANK ACCOUNTS 1 2018 https greatdemocracyinitiative org wp-content uploads 2018 06 FedAccountsGDI pdf 34 Alexandre Berthaud and Gisela Davico “Global Panorama on Postal Financial Inclusion ” Universal Postal Union March 2013 Available a 35 Kevin Wack When a Small Town Loses its Only Bank Am Banker Feb 2 2020 https www americanbanker com news when-a-small-town-loses-its-only-bank 36 Postal Facts at https facts usps com size-and-scope Terri Friedline Mathieu Despard Mapping Financial Opportunity Final Report 8–9 2017 https aedi ssw umich edu sites default files publications Mapping-Financial-Opportunity pdf https perma cc V5AF-2FLF 37 https morningconsult com most-trusted-brands mod djemCMOToday 38 For more information see Baradaran How the Other Half Banks supra note 6 39 For revenue projections for the post office and market share of AFS spending see U S Postal Service Providing Non-Bank Financial Services for the Underserved 2014 https www uspsoig gov sites default files document-library-files 2015 rarc-wp-14-007_0 pdf See Mehrsa Baradaran A Short History of Postal Banking Slate Aug 18 2014 https slate com news-andpolitics 2014 08 postal-banking-already-worked-in-the-usa-and-it-will-work-again html https perma cc F6M5-22CA 40 Aaron Klein Real-time payments can Help Combat Inequality Brookings March 6 2019 https www brookings edu opinions real-time-payments-can-help-combat-inequality The Federal Reserve has stated that it is studying the issue but the recently-introduced Payments Modernization Act seeks to speed the process along and mandate a real time payments system John Heltman Democrats try to Force Fed’s hand on Faster Payments Am Banker July 24 2019 https www americanbanker com news elizabethwarren-other-democrats-look-to-force-feds-hand-on-faster-payments Faster Payments Task Force Bd of Fed Governors Sys The U S Path to Faster Payments 2017 https www federalreserve gov newsevents pressreleases files US-path-to-faster-payments-pt1201701 pdf Fed Reserve Sys Strategies for Improving the U S Payment System Jan 26 2016 https fedpaymentsimprovement org wp-content uploads strategies-improving-us-payment-system pdf 41 Real-Time Payments What Where and When NCR 2020 https www ncr com company blogs financial real-time-payments-what-where-and-when 42https www uspsoig gov sites default files document-library-files 2017 RARC-WP-16-007 pdf 43 Louis D Brandeis Other People’s Money and How the Bankers Use It 64 1914 9