Ms. Jennifer J. Johnson
Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue, N.W.
Washington, D.C. 20551

Re: Docket No. R-1037; Modifying Federal Reserve ACH Operations and Pricing Practices Relative to Private-Sector ACH Operators

Dear Ms. Johnson:

The Treasury Management Association (TMA) welcomes the opportunity to comment on the benefits and drawbacks of modifying the Federal Reserve Banks' pricing practices and deposit deadlines for ACH transactions they exchange with private-sector ACH operators.

TMA represents more than 12,000 finance and treasury professionals who, on behalf of 5,000 corporations and other organizations, are significant participants in the nation's payments system, and particularly in the ACH Network. Organizations represented by its members are drawn generally from the Fortune 1,000 companies and the largest of the middle market companies. TMA members bear primary responsibility for the receipt and disbursement of their organizations' payments and thus have a sizeable stake in the maintenance of a secure and efficient payment system.

TMA has long supported the federal government's efforts to encourage the migration from paper to electronic payments. In the Association's view, the electronic delivery of payments and payment-related information enhances the productivity and competitiveness of the American economy by providing a cost-effective, safe and efficient means of transacting business.

The ACH Network is one of the nation's primary electronic payments systems, whose ability to innovate and responsiveness to user needs have a critical bearing on the growth of electronic commerce. The Federal Reserve Board stated in its request for comment that it "historically has stressed the benefits of competition in the provision of payment services." TMA agrees with this principle, in the belief that a competitive marketplace leads to innovation, cost-savings and higher quality service. Regulatory action that strengthens competition in the ACH Network on which TMA members rely so heavily for the origination and receipt of electronic payments has the strong support of the Association.

TMA is aware that the National Automated Clearing House Association (NACHA) has filed a comment letter with the Federal Reserve Board recommending that the Federal Reserve reflect private-sector practices in its pricing and file delivery deadlines as they relate to private-sector operators. TMA has reviewed NACHA's response and shares the view that the adoption of the measures proposed by NACHA would introduce competitive equity between the Federal Reserve ACH Operators and the private-sector ACH Operators, increase the flexibility of the ACH Network, and enhance its ability to respond to the needs of its corporate users.

TMA looks forward to continuing its cooperation with the Federal Reserve Board to promote the migration to electronic payments.

Sincerely,

/s/ Nolan L. North, CCM
Vice President and Assistant Treasurer
T. Rowe Price Associates, Inc.
Chair
TMA Government Relations Committee