Re: Mailing Currency (88 Fed. Reg. 3944)
United States Postal Service
475 L’Enfant Plaza SW
Room 4446
Washington, DC 20260
To Whom it May Concern:
The American Bankers Association (ABA) respectfully requests that the United States Postal Service (Postal Service) extend by at least six months the effective date for its proposed rule amending their mailing standards for currency that was published in the Federal Register on January 23, 2023. As you know, the proposed rule would require commercial cash deposits over $500.00 be sent using the Registered Mail service. The comment period deadline for the proposal is February 22, 2023, with an effective date of March 1, 2023.
We support the Postal Service's efforts to address the serious issue of mail fraud while also satisfying the mailing needs of business customers looking to mail their cash deposits. However, ABA is concerned that the proposed rule's effective date does not provide retail businesses, banks, and other third-party servicers enough time to change their processes for depositing mail cash deposits over $500 via Registered Mail.
Many retailers use the Postal Service's Priority Mail service for their cash deposits and schedule package pickups. Upon receipt of the package at the retailer's location, the Postal Service scans the mail, and the retailer is provided with a tracking number. Retailers use Priority Mail because of the significant costs associated with hiring armored carriers to pick up cash, having employees travel to a bank branch to deposit cash, and using remote cash capture technology such as smart safes. They may also have safety concerns about holding cash overnight. The proposed rule would have a significant effect on retailers with a low to medium volume of customer cash transactions (e.g., tax preparers, general merchandise stores, healthcare providers), but not high enough to financially justify the beforementioned alternatives for depositing cash.
Currently, banks do not have in place processes for depositing mail cash deposits via Registered Mail, which requires signature upon delivery for every piece of mail as cash vault management in general does not accept Registered Mail. Third parties such as armored carriers and deposit tracking servicers would also need to change their processes to comply with Registered Mail requirements. For example, under the current proposal, an armored carrier would need to sign for every piece of mail upon pick up at the Post Office. As such, the Postal Service might conclude that it would be sensible to change Registered Mail procedures and allow for one signature to pick up multiple packages.
While some retailers may be interested in the Registered Mail option, they too will face difficulty in implementing these changes by the Postal Service's effective date, especially those with a larger geographic footprint across multiple locations. On the contrary, retailers not interested in the Registered Mail option may instead opt to mail multiple cash deposits via Priority Mail to avoid trips to a Post Office. A package mailed via Registered Mail with a declared value of $1,000 has a fee (in addition to postage) of $20.35. In contrast, two Priority Mail flat rate envelopes (12-1/2" x 9-1/2”) neither weighing more than one pound, with each having a declared value of $500, and mailed in Zone 1 (local shipment), costs $19.30. As such, ABA recommends that the Postal Service engage with all stakeholders on the most appropriate dollar threshold to assist business customers in meeting their mailing needs while also providing a secure service. Conducting a study to find the average value of mailed commercial cash deposits would assist the Postal Service in these efforts.
Finally, it should be noted that the issuance of the proposed rule on January 23 coincided with the official start to the 2023 tax filing season when the Internal Revenue Service began accepting 2022 tax year returns and marks an especially busy time of year for businesses.
For the reasons previously stated, an extension of the effective date with an additional six months until September 1, 2023, would enable banks, retail businesses, and all third parties adequate time to implement these changes.
If you have any questions, please contact me at [email protected] or 202-663-5519 if you would like to discuss this further.
Sincerely,
David Androphy
Senior Manager, Prudential Regulation & Asset Management
American Bankers Association
