Joint Trades Letter to the Fed re: Fedwire Funds Services ISO 20022 Conversion

Dear Mr. Gould:

We, the undersigned associations representing financial institutions, formally thank you for the four-month extension to the Fedwire Funds Service ("Fedwire") conversion to the ISO 20022 standards. The Board of Governors of the Federal Reserve System ("Board") proposed to leave the proprietary Fedwire Application Interface Manual ("FAIM") format through a single-day March 10th conversion, which financial institutions generally support. However, our memberships felt additional time is needed for all stakeholders to complete testing and expand dress rehearsals to ensure a seamless transition to ISO 20022.

Fedwire directly or indirectly facilitates almost all transactions by being a primary payment source for financial institutions to transact with other institutions, such as the clearing and settlement of all payment types and to transfer funds. Consumers access the Fedwire system when they "send a wire." The average Fedwire daily volume is over 800K transfers and $4.4 trillion in value. Fedwire is the critical hub in the banking system infrastructure.

We support ISO 20022 standards and the Fedwire implementation. The ISO standards include basic formatting standards such as First Name and Last Name formatting, and address standards. Federal Reserve Board Services ("FRB Services") provides testing opportunities, and there has been significant education and outreach. The industry requested that Fedwire not convert for at least one year after rollout of FedNow, and we appreciated the nearly 18 months with FedNow, an ISO 20022 message system.

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