For the past two years, we’ve been advising financial institutions to add both the FedNow® Service and RTP® Network to their digital payments offering. From the start, our mantra has been, “Receive now, receive on both, and decide later which network to send on.”
The rationale was simple:
- Why miss out today on easy deposits from receiving instant payments?
Once applications that benefit your accountholders come to market, you’ll have the data you need to inform your strategy for sending instant payments.
- Now here we are in 2025, the proclaimed year of sending instant payments, and applications for community banks and credit unions are finally arriving in force.
"Wait and See" No Longer Stands
That’s right, the time has come for you to begin to implement your strategy for sending instant payments … but how?
When things feel too complicated and cloudy to sort out, I like to lean on the wise words of Dr. Seuss for a little confidence boost: “Oh, the THINKS you can think, if only you try!”
But in case you need more than encouragement, here’s a handy three-pronged approach to thinking through your instant payments Send strategy.
1. Think About Your Accountholders First
As you begin to prioritize your initial use cases for Send, consider first the needs of your current customers or members. What will enabling them to send money instantly make possible?
Your retail accountholders stand to receive a financial health benefit from tighter control of their cash flow, plus an experience benefit from uninterrupted delivery of funds. That’s why one of Jack Henry’s first offerings for Send with FedNow and RTP is an open-loop P2P option from Payrailz®. On the flip side, your institution stands to keep more of their deposits.
If your institution is business-focused, your very first step may be talking with your largest corporate clients about their evolving needs. (And you may want to do so quickly, before a competitor uses the ability to send instant payments to pry them away.) Or you may want to provide business customers with a lending-side proof of concept to better position your institution as a go-to for loan origination and escrow support. Or maybe you want to facilitate timely brokerage transfers for the high-net-worth owners of those businesses.
Whether you lead with retail or business, we believe the optimal way to implement instant payments is with trusted customers and at lower volumes (initially). A gradual start will allow you to smooth the transition as you refine your processes, address any challenges, and minimize potential disruption. Which leads into our second recommendation.
2. Let Risk and Compliance Set the Pace
Don’t add new programs more quickly than your risk and compliance teams can manage. Remember they need to perform risk reviews and develop appropriate policies and procedures.
I want to emphasize you will be learning new concepts along the way to operationalizing sending instant payments. Most will revolve around liquidity.
While the use cases above are good ideas, leading with all of them at the same time may not be. Don’t get ahead of your operations and risk staff.
If you are one of those institutions that took our early advice on receiving instant payments, you’ve seen how those payments flow 24/7. You’ve likely also seen the biggest volume on Fridays from 5 to 7 p.m. In fact, the RTP Network says 42% of transactions occur on weekends, evenings, and holidays.
All this is to say that outbound instant payments will surely impact your operational processes and your standard compliance responsibilities.
A prime example is the need for participants to maintain adequate balances at all times, because instant payments process and settle continuously. Doing this well requires thinking through your liquidity management plans, especially if your institution finds itself being a net instant payments sender. The first thing you’ll want to determine is whether liquidity management is something that can be handled internally. If not, you’ll need the services of a banker’s bank or corporate credit union.
Then there are the core compliance activities around AML/BSA, sanctions screening, and KYC. Adding a new source of transactions doesn’t mean changing your general programs, but it does involve making sure reporting is updated appropriately and processes are reviewed to include the new payment types. You don’t want to provide access to sending instant payments without corresponding controls, because instant payments are irrevocable.
Finally, if you are considering engaging with third parties, your compliance teams must conduct thorough due diligence and plan for continuous monitoring of those relationships. Mitigating potential vulnerabilities and meeting the expectations of regulators may require additional staffing, as well as customized processes and procedures for the specific third-party programs.
3. Think Beyond the Digital Platform
If you aren’t considering use cases beyond your digital platform, you aren’t doing your accountholders any favors.
While offering ways for individuals and businesses to self-serve within your digital platform is a good start, consider where else your customers and members are transacting.
Whether you engage with third parties as a sponsor institution, or support integrations directly into accounting packages or ERP systems, it’s important to understand how to place new instant payments opportunities where your accountholders find value.
There is no one-and-done answer to supporting instant payments. The interface needed for a consumer to send a friend money will not be the same as the interface to support corporate accounts payable processes. Small- and micro-businesses will have different needs than large conglomerates with high-volume use cases.
It's Time to Start Sending!
As FedNow and RTP pave the way for faster, more efficient transactions, we believe community banks and credit unions can chart a winning path for instant payments by addressing key risk and compliance challenges and growing the ability to both send and receive them.
That’s why we recommend you start with your accountholders, don’t go faster than your compliance and risk teams, and think beyond your digital platform.
The time has come for a new instant payments mantra: “Choose a rail, choose a way, be a sending FI!”
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