Today, the ACH service exhibits economies of scale over broad volume levels, which suggests that BIS Review 31/1998  -4-  efficiency may be enhanced and unit costs minimized by having few ACH operators. Thus, the Federal Reserve may have an advantage because it processes the large bulk of ACH payments.
We believe that the competitive environment that results from multiple ACH operators will best ensure continued efficiency improvements and innovation in this service. I believe it is important that the Federal Reserve take appropriate steps to stimulate the competitive environment in the ACH.