The Federal Reserve Board ("FRB") is considering upgrading the U.S. payment system to provide payment-by-payment interbank settlement in real time (i.e., real-time gross settlement, or "RTGS").

On October 3, 2018, the FRB requested comments from the public on (i) the adoption of an RTGS settlement service, which would enable settlement on a 24/7/365 basis, and (ii) whether the FRB or the private sector should provide a liquidity management tool in support of RTGS settlement services. Comments on the FRB's potential actions are due by December 14, 2018.

In remarks before the FedPayments Improvement Community Forum, FRB Governor Lael Brainard stated that the U.S. payment system is "at a crossroads" due to the growing gap between what we need and expect in digital transactions and the underlying settlement capabilities. Ms. Brainard warned that payments rely on a "patchwork of systems" that can cause "inefficiencies and delays, as well as uneven access." Although RTGS may be operationally demanding, Ms. Brainard stated, it would reduce risk by eliminating the need for deferred interbank settlements, which are effectively "IOUs" between banks, and increase the overall efficiency of the U.S. payment system.