ICBA responded to a Federal Reserve Board request for comment regarding a proposed change to its policies for measuring intraday credit or daylight overdrafts in financial institutions’ accounts at Federal Reserve Banks.

Despite general support of the policy change designed to prevent outgoing Fedwire transfers from breaching the sender’s ceiling on its total daylight overdraft position, ICBA voiced concerns regarding the uncertainty of specific handling of a rejected Fedwire transfer.

Under the Reserve Banks’ pilot program, Fedwire transfer senders have the “opportunity to verify authorization and authenticity and to fund the transaction.” ICBA advocates applying the pilot’s approach if the Board expands real-time monitoring to include all outgoing Fedwire transfers.