Payment Innovation & Regulation

Vast Federal Reserve & Payments Industry Experience

As counsel to the Fed’s Retail Payments Office, Richard Fraher:

Led the legal team that wrote the Reserve Banks’ operating circular provisions and the Fed’s service agreements for image based check handling and returns. 123

Created the operating circular provisions for the FedACH risk management services and the Fed’s same day ACH service

Helped to design and wrote the rules and agreements to support FedGlobal ACH

Served as special advisor to the steering committee that established the International Payments Framework and architected the initial IPFA rule set

Served as a leading voice in payments law and regulation for the industry by presenting on emerging legal, regulatory, and supervisory concerns at payments conferences in the U.S., Europe, and Latin America

Mr. Fraher has a tremendous amount of knowledge and practical legal and compliance experience in the payments industry. Through his extensive involvement with assisting the financial industry decipher payments law, Mr. Fraher consistently provides a practical and strategic compliance approach for helping financial organizations grow. His consulting style significantly helps break down complex payment’s laws to ensure a business understands their risks, complies with regulatory and network rules while also enhancing their payments business.

Terri Sands

President, Secura Risk Management

I have worked with Dick on some very complex payment system issues and I have had the privilege of making numerous presentations with him at conferences and banking schools. Without a doubt, he is the number one expert on Federal Reserve regulations and Operating Circulars related to payment system issues including checks, wire transfers, and ACH transactions. Dick has exceptional analytical skills, and having drafted Federal Reserve regulations and Operating Circulars he uses his extensive knowledge of those regulations and the Uniform Commercial Code to resolve complex issues and to present the resolutions in a clear manner in layman’s terms. Whenever I have a check, wire transfer or ACH related matter, I call Dick.

Paul Carrubba

Owner, Carrubba & Associates LLC, Of counsel, Adams & Reese LLP

Richard Fraher has been an outstanding resource for the members of Macha and myself professionally. We have often called or emailed Dick when one of our members has questions on regulations or payments in general as we know he knows the answer. or knows how to find it. He is extremely knowledgeable and an excellent speaker. We have had him present many times on regulations at conferences and payment schools, and he kept everyone’s attention even in the dreaded after lunch hour. He always received great comments and everyone attending the conferences requested we have Dick return.

Mary Gilmesiter

President & CEO, Macha/PAR

Dick has the deep knowledge and understanding of the history, legal and policy considerations, politics, and operational details to thoroughly analyze issues relating to US and international payments. As an experienced professor, he can explain concepts clearly, provide examples and perspectives, and understand questions and how to respond to them. He is an expert on many facets of payments systems, including ACH.

Jeanette Blanco

General Counsel, NACHA