2025年3月10日 FEDWIREはISO 20022に移行

Well, I was wrong, as were most of the industry, but I suspect we’re largely happy nevertheless.

I refer to the announcement, finally, on June 27 that March 10 2025 will the cutover date for FedWire to ISO 20022. Conversations at Nacha reflected the majority of the comments on the end date consultation. Instead of a 6-12 months delay though, with most thinking it'd be Sping 2024, it is 18 months, Spring 2025. Notably, it's still behind CHIPS who remain committed to the original date of November 2023. Perhaps more wrong were the group of banks who believed that it would be “another Durbin”, referring to ever shifting implementation dates.

What else did we learn?

• The move to 24/7 access seem to have been put on hold, which while disappointing, is probably sensible. Given the challenge that even March 2025 will pose for many banks, it makes sense to descope things that can be implemented later.
  
  
• There will no "translation” service, which we believe is a good thing. While this would have helped, there was a very real danger that it would have become the default approach for some banks, and become a barrier to adoption rather than a bridge.
  
  
• FedNow implementation has been prioritized over FedWire which has raised some eyebrows. FedNow isn’t mandatory, was started later, and only a small portion of the banks impacted by FedWire will adopt FedNow, at least straightaway. On the positive side, it will act as a practice run for FedWire.

There were a few disappointments.

• “the Reserve Banks are developing a communication and education strategy that is intended to promote industry readiness.”
  While the industry acknowledges that the Fed are doing something already, I think many are disappointed that this education piece isn’t in full swing already. There are still many banks who have yet to grasp the size of the challenge ahead of them and their choices, instead of being underway on their projects. Furthermore, corporates seem to be unware of the changes at all. This awareness will be tested in a Celent survey of banks and corporates in the next month or so.
  
  
• "the Reserve Banks will soon publish the ISO 20022 message format specifications for the Fedwire Funds Service on the MyStandards application”.
  Again, many are surprised that this critical element isn’t ready. That makes it challenging for the vendors to be completely ready, and who the banks are relying upon. We hope that this key piece is in place shortly.

Now is the time for the banks to accelerate their programmes. With a date in place, there is no excuse to delay. As Celent has mentioned many times before, banks have traditionally migrated close to the deadlines, in part as they struggle to get there. Given though that the constraints are likely to be at the Federal Reserve (as in, there’s only one of them and 4,500 banks) and a handful of vendors, starting as early as possible will be key.