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3. "A substantial wind-down of the Reserve Banks'
The total value of checks cleared check services." This would eliminate "significant
operating costs."
in the United States rivals the 4. Making the investments necessary to upgrade the
nation’s GDP. aging check-processing infrastructure. This would
increase operating costs, which then would need to
be recouped through higher service prices.
It's not just large corporations that rely on checks. "Many Comments skew toward spending money
small businesses will depend upon check services for the
foreseeable future," the National Federation of Independent The deadline for public comments is March 9, 2026. But
Businesses wrote in a letter responding to the RFI. It urged as of early February, the Fed had received well over 200
the Fed to not employ any strategy to wind down check comment letters, most of which seem to oppose any
services. degradation of services.

The payments association EPCOR polled its membership This comment from North Star Community Credit Union,
(largely financial institutions) and reported that 85 percent in North Dakota, expressed a prevailing opinion of small
see Reserve Bank check services as important despite financial institutions. "The Reserve Banks provide a
declining volumes, "particularly for B2B payments, rural neutral, resilient infrastructure that promotes equitable
communities and legacy workflows." It said members access, competition, and operational reliability – especially
emphasized the Fed's "value as a neutral provider that for community banks and credit unions that may not have
supports stability, risk mitigation and interoperability – viable private sector alternatives at scale. A significant
especially for community banks and credit unions." reduction or winding down of these services could
disproportionately impact smaller financial institutions
The nub of the Fed's thinking and the communities they serve," North Star stated.
"As the total number of checks processed by the Reserve "For these reasons," the credit union added, "continued
Banks declines, the long-term viability of the Reserve investment in and support of Federal Reserve check
Banks' check services is increasingly at risk," the Fed services is necessary. Any future strategy should preserve
explained in its RFI. With most of the costs fixed there a baseline level of service that ensures checks remain a
is "little room for additional cost reductions or efficiency reliable and accessible payment option."
gains that would allow the Reserve Banks to continue
providing the same level of check services at current First Bank and Trust in Brookings, S.D., wrote, "In our
prices while still meeting the cost recovering requirements view, check usage is unlikely to materially change over the
established by the MCA." next three years within our communities. However, over
the next decade we expect a significant reduction as digital
The MCA requires the Fed to recover the full cost of payment tools become more user-friendly, broadband
providing payment services, pricing those services as access improves, and generational shifts occur. A long-
though it were a private-sector for-profit enterprise. term transition strategy should therefore be intentional,
gradual, and centered on accessibility, affordability and
"Given the magnitude of potential investments, declining consumer readiness."
volumes, and trends in the check market more broadly, the
Board believes that the time is appropriate to analyze a Consumers who submitted comment letters (and there
range of possible strategies for the future of the Reserve were dozens), don't seem ready for an economy where
Banks' check services," the Fed stated in a memorandum checks are no longer a payment option. Several cited the
accompanying its RFI. fees associated with electronic payment options, as well as
hacks involving credit and debit cards, as their reasons for
It offered the following four potential strategies: wanting the Fed to continue supporting check payments.
1. Continue providing services as they exist today,
with no money spent to improve or enhance check "One would think the last thing the government would
services. Over time, of course, this will lead to a want to do is increase customer cost and aggravation by
"significant" degradation of services, leading to this action while also diminishing the ability for regular
frequent operational issues and extended service folks to pay their bills on time," wrote one consumer.
outages.
2. A "simplification" of check services, including "My personal opinion is to upgrade the infrastructure, but
with money appropriated by Congress," wrote another.
discontinuation of "certain offerings." This would (No tax dollars are used to fund Fed operations. Its
entail minimizing infrastructure investments, and payment system services are funded entirely by fees FIs
"material changes" in the level of service offerings.. pay for those services.)
For example, limiting hours of operation.

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