On Oct. 31, 2019, Nacha submitted a comment letter to the Federal Reserve Board of Governors in response to the recent notice and request for comment regarding the proposal to develop a new real-time payment and settlement service, called FedNow. In the letter, Nacha urges the Fed to not let work on the FedNow initiative detract from the pending proposal, and the more immediate need, for the expansion of the National Settlement Service (“NSS”) and Fedwire operating hours.