ICBA filed comments on the Federal Reserve's proposed amendments to Regulation J, which would allow FedNow participants to use non-Reserve Bank intermediaries to enable cross-border payments. ICBA did not object to the proposal and supported its overall objectives.

ICBA raised concerns about BSA/AML and sanctions compliance in a 24x7x365 instant payments environment, eligibility safeguards against nonbank access, community bank cost considerations, and a reasonable implementation path including a six-month transition period and a two-year post-implementation review.