Board of Governors of the Federal Reserve System

While I support the concept of the Federal Reserve developing a payment account prototype that it might provide to legally eligible institutions, I cannot support this request for information (RFI) because it is not sufficiently specific about safeguards to protect against the accounts being used for money laundering and terrorist financing by institutions we do not supervise. While I dissent on the RFI, I will be interested in reviewing public feedback about how such safeguards could be designed and implemented, as well as comments on how to mitigate other risks of the payment accounts. I remain open to supporting a revised framework.