Ray Mulhern, Senior Vice President, The Clearing House
Abstract
As the most wide-sweeping overhaul of the US financial industry seen in decades, Dodd–Frank dramatically changes the existing regulatory environment, amends the Federal Reserve Act as well as numerous other federal laws, and establishes tighter supervision standards to protect the US economy. It will profoundly affect all: consumers, businesses, financial institutions and the regulatory infrastructures themselves. At over 2,200 pages, this legislation is just the beginning. Existing and newly minted regulatory bodies must now write the rules that will implement the provisions of Dodd–Frank. Comments on proposed rulemaking will certainly influence outcomes. Several of these rulemaking deadlines will fall due between the time of this writing and the actual publication date, so clarity and specific details around many of the components of the Act are not complete at this time. Given the complexity of Dodd–Frank and its sprawling scope, this article focuses on just a few of those key components of Dodd–Frank that most directly affect the payments environment.
Keywords
Dodd–Frank, payments, financial stability, financial reform, regulatory reform, interchange, debit card, systemically important
Ray Mulhern is Senior Vice President, The Clearing House, responsible for CHIPS Product Management and Strategy. As President of The M Consulting Group, he has assisted banks and corporations with enterprise-level payments strategy and payments systems infrastructure. In his 30 years of experience in the operational, sales, marketing, strategic planning and product management aspects of the global payments industry, he has held a variety of positions, beginning with the Irving Trust Company, The Bank of New York, First Union/Wachovia Bank). He is a published author of numerous articles on payments-related topics and is a frequent speaker on industry issues at major domestic and international conferences such as SIBOS, International Payments, NACHA, AFP, SWIFT Operations Forum Americas and BAFT-IFSA. As a former member of Wachovia Bank’s Payment Strategies Group, he has hands-on experience of the development and execution of enterprise payments strategy. He has been active in forward-looking industry forums, a former officer and board member of BAFT-IFSA, former Director of EastNets Group, and former member of Federal Reserve Bank’s Payment Risk Committee. He is skilled in the fundamentals of key non-credit services for banks and corporations, including Vendor Selection and Negotiation, Financial Analysis, Payments Regulatory Environment, Global Liquidity Management, Project Management, Product Management, Strategic Planning, and Global Payments Clearing and Settlement Infrastructures (ACH, Fedwire, CHIPS, EBA, CHAPS, TARGET2, CHATS, SWIFT, etc.).
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