
David Portilla
59:00 - 60:09
"there is no federal preemption for payments outside of the National Bank Charter. And so right now when a firm that's focused on payments activity would like to operate nationally, their options are to operate under a multistate framework that is not fully interoperable or to apply for a national bank charter that is not really fit for purpose."
“there is no federal preemption for payments outside of the National Bank Charter. And so right now when a firm that's focused on payments activity would like to operate nationally, their options are to operate under a multistate framework that is not fully interoperable or to apply for a national bank charter that is not really fit for purpose.”
At the same time, speak to where there are areas where we do need a uniform national framework, where that is preferable. For example, are there aspects of payment regulation such as interoperability, nationwide market access, or regulatory certainty where greater consistency across jurisdictions would better support innovation and competition while still preserving the benefits of our dual banking system Obviously, when we're talking about payments in a modern world, we're talking about interstate commerce. Yeah, that's right, and I think that highlights the limitation of the state system, which is that at a certain scale, a business needs to operate nationwide under a uniform set of standards. As I noted in my remarks earlier, there is no federal preemption for payments outside of the National Bank Charter. And so right now when a firm that's focused on payments activity would like to operate nationally, their options are to operate under a multistate framework that is not fully interoperable or to apply for a national bank charter that is not really fit for purpose.