CFA joined a coalition of consumer, small business, civil rights, community and legal service groups in comments to the Federal Reserve Board’s (FRB) in response to proposed rules for implementing the FedNow payment system. The groups recognize that a FRB real time payment system can provide competition and, if properly designed, can ensure that all consumers and businesses benefit from the widespread availability of person-to-person payments systems and faster financial transactions. However, the coalition highlighted the need to ensure rigorous protections as the FRB develops the FedNow service in order to ensure that the system is safe to use. The groups argued that the FRB should not launch the FedNow service until sufficient protections ensure that the service is safe and reliable for consumers and small business users, and that the proposed rules do not meet that standard. In particular, the system must protect consumers and small businesses from fraud and mistakes. Scams and errors can be devastating and have a particularly harsh and targeted impact on low-income families and communities of color.