The collapse of Silicon Valley Bank was the first real demonstration of a bank run in the digital age. Twitter- and WhatsApp-fueled panic pushed countless CEOs into a frenzy
In the background, the delay in wire execution bought SVB and policymakers some (though limited) time to address the rapidly devolving situation, work to manage the contagion and search for emergency liquidity. In the future, thanks to real-time payments, they may not have as much time to react. A crisis could quickly spread to other banks, especially regional banks. With the Fed's
Banks and regulators will have an even more challenging time addressing bank runs in an economy driven by instant payments. They must establish guardrails to ensure that real-time payments do not foster future banking crises by enabling swifter and more consequential runs on banks.
This is not an indictment of real-time payments — they provide immense benefits to the U.S. economy. Businesses that utilize real-time payments will have a more cost-effective and efficient payment system than wires or checks and far greater liquidity management. Consumers will have immediate access to their money, 24 hours a day, seven days a week, helping many prevent late fees and overdrafts by using instant bill pay. Consumers and merchants are clearly looking for a more efficient, secure and accessible payments option. Real-time payments will provide this.
A House hearing showcased a bipartisan consensus on the need to regulate stablecoins, but the parties disagree down to the definitions, making the legislation's future uncertain.
Treasury Secretary Janet Yellen has already
The most obvious first requirement centers around velocity limits. As of now, depository institutions on The Clearing House's RTP network must
Financial institutions will have to ensure that their velocity limits reduce the potential for rapid, massive deposit outflows and that these limits can be quickly adjusted in the case of a major scare. While velocity limits may hinder the utility and benefits of real-time payments in a small percentage of transactions, given the fragility of the banking system, policymakers would serve their financial institution constituents well by following these steps: recommending velocity limits, providing economic intelligence and alert services for real-time payment providers on potential bank-run inducing events, and ensuring responsive support for financial institutions seeking to alter their velocity limits.
We also advise financial institutions, both big banks and regional players, to get on the same page on such limits to ensure there is not a "race to the top" in which banks provide higher transaction limits to outcompete other banks. Market forces ought not to incentivize banks to create new risks through their real-time payment transaction limits during precarious economic times.
Financial institutions should also take incremental steps in adopting real-time payments. This could include first accepting real-time payment deposits from customers, followed by withdrawals thereafter. This would enable banks to better understand real-time payments operationally before supporting instantaneous customer withdrawals. At the same time, banks must implement robust verification and authentication processes for every transaction to prevent fraud and abuse, including account takeover attacks. These measures could include out-of-band verification for large transfers.
Real-time payments will pose new opportunities and challenges. As the entire financial sector navigates a turbulent time, decision-makers must ensure that we do not sacrifice stability for speed, while also keeping an eye focused on future payments innovation.