Response to ISO 20022 Proposal

Ann E. Misback, Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, NW
Washington, DC 20551

Dear Ms. Misback,

The American Bankers Association (“ABA”) appreciates the opportunity to comment on the Notice of Adoption of Message Format and Request for Comment (“Notice”) regarding the Fedwire© Funds Service (“Fedwire”) and ISO 20022. ABA supports the migration to the new message format that allows for greater detail to be associated with each payment. We believe that a well-executed implementation plan is essential for the switchover in November 2023 and recommendations to achieve this are included in this response.

The Notice plans for making the migration to ISO 20022 for Fedwire on a single day no earlier than November 2023 instead of the phased approach originally considered in 2018 and later postponed. A single day switch means that all participants in the system must have thoroughly tested their systems rigorously or the system will be disrupted.

It is important to note that in addition to Fedwire, The Clearing House also operates the private sector wire clearing system, CHIPS. Any transition to ISO 20022 must be carefully coordinated between the two systems.

Download the comment letter to read the full text.