Re: Input needed: US Federal Reserve Payments Position Paper

On 12/9/13 6:42 PM, Manu Sporny wrote:
  > Very helpful, thank you. I'd love for you to have a second look and
> give further feedback if possible.


OK, done, got to the end this time! Some great stuff in there, I hope 
the right people read it at the Fed. :-)

Here are my personal opinions on what I'd change if I had to hand this 
in tomorrow.

Comments on the Monday Dec 9 EVENING (revised) version:

Executive Overview:
Good

Improving the Automated Clearing House (ACH) Network:
     1st paragraph has three errors or clumsy points that make it 
incomprehensible on an attempted read:
     1. Missing word: “US financial system should constrained” should 
be “US financial system should [be] constrained”
     2. Second sentence very clumsy. I suggest replacing with:
“Current-generation financial networks provide fundamentally better 
technological solutions to ACH[; these can’t be caught up to by 10 
years of incremental evolution of the ACH,] the gap is simply too wide.”
     3. Third sentence, the words “has a number of features…(such as…” 
I believe are misleading, making the sense ambiguous: it implies that 
‘anti-money laundering’ and ‘native Know-Your-Customer’ are features 
of Bitcoin, which is nonsensical. I suggest changing to:
     “For example, while the Bitcoin network [lacks] a number of 
features that [make it incompatible] with a global payments system 
(such as anti-money laundering protections and native 
Know-Your-Customer implementations).…”

Simplifying the Governmental Regulatory Environment:
     All comprehensible, however I think there’s one large sequence 
flaw: The first two paragraphs seem to me to be an *example* of the 
larger set of simplifications and offers that are explained by the 
subsequent three paragraphs. This disoriented me.

In other words, the level of abstraction from the previous section -- 
Bitcoin etc. vs. ACH, in a 10-year time-window of comparison -- would 
seem better matched if you started this section with the third 
paragraph, as:
     “The adoption of the technologies being created by the Web 
Payments group could ease the regulatory burden placed on both the 
regulated and the regulators….” etc.
and continued to the end of the ISO/IEC JTC list,
     THEN
put in the first two paragraphs, starting with something like “[As an 
example of the type of change we believe we can advise the Fed on, 
take the fact that] the per-state regulatory framework on Money 
Transmitter Licensing in the United States is particularly hostile…” 
and continue to the end of the second paragraph.
     THEN
finish as it now stands, with the final short paragraph “The Web 
Payments group at the W3C…”

A Layered Approach to Payment System Improvements:
Good

An Introduction to Web Payments:
     Not sure this section is needed at all, and it may be 
counterproductive to include it. Some parts definitely overkill in a 
marketing sense, as if it was written for someone else and copy-pasted 
(was it?) :-)

Web Payment Requirements:
     Good, except the first word of final paragraph; for reasons 
already given (marketing) I’d cut “Fortunately” and start with “The 
Web Payments group…”

A Flexible Identity Solution:
     Title seems like a business-buzzphrase because of ‘solution’ 
being overused in the last decade, especially in IT.   I’d prefer if 
it was titled just “Flexible Identity” or something.
-- the third bullet point I believe has clumsy split phrases that 
puzzled me; I’d suggest:
     “It must support the attachment of verifiable machine-readable 
information[ to the identity by 3rd parties, such as a 
government-issued electronic passport.]”
-- final sentence of 2nd paragraph: you have a compound (plural) 
subject and singular verb, doesn’t agree. Should be:
     “This identity mechanism and the functionality it enables [are] 
at the heart of the Web Payments work.”

Decentralized Products and Services:
Good.
     Although *finishing* with “more effortlessly file their taxes” -- 
especially since you’ve already referred to ‘more accurately levy 
taxes’ in the just-previous sentence -- seems like it might be taken 
as ass-kissing. ;-)

Purchase Requests, Contracts, and Receipts:
     Good, *except*, your repetition (cut and paste) of the whole 
first part of the final paragraph from the same paragraph in the 
previous two sections seems like overkill -- although maybe they asked 
you the question in these words, or something, and told you to repeat 
it?  ☺ -- But to me, the final paragraph would be much stronger as a 
whole, and would finish the section nicely, if it said:
     “This [system] should be of particular interest to the US Federal 
reserve because all of these digital purchase and receipt 
technologies…” etc.

The Web as the Global Financial Network:
Good.


------

Steven Rowat

Received on Tuesday, 10 December 2013 04:39:13 UTC