Peter Ihenacho

Getting the fed to do this is essential for getting payment processors to stop censoring the internet. Here's my full comment if anyone wants to copy my homework (but please put it in your own words so it doesn't look like we're botting): Payment processors, banks, and other middlemen should not control commerce. Debanking and similar practices, in all their forms, should be banned outright wherever possible and restricted in all available ways where that is not possible. The phone company does not disconnect your call if they don't like what you're saying. UPS doesn't look inside your package and refuse to deliver it if they disagree with its contents. This is how the transfer of money between willing participants in transactions should function, and the middlemen who facilitate those transactions should be treated like common carriers. Without doing this, the entire economy is hostage to the whims of a few bankers. Every year, more and more business takes place online and with electronic transactions rather than face to face with physical cash. Thus, every year, banks and payment processors, and the neutrality thereof, become more essential to a free and functioning market. "Reputational risk" standards expose people and organizations to the risk of getting their financial lives deleted and their existence made impossible whenever a financial institution doesn't like them or a pressure group pushes hard enough for it. If you're on the left, you should worry about how this routinely happens to controversial activists and adult content creators. If you're on the right, you know it's been done to faith groups and gun sellers too. Getting rid of this isn't a partisan issue, it's a necessary part of having a free market and free speech. The free market itself is also not a defense of these practices. Banking is more dominated every year by a few big players financialbrandforum.com/wp-content/upl… removing free market defenses against debanking, such as taking your business to another bank. Those big financial institutions also tend to move together as a cartel. After January 6th, white nationalist Nick Fuentes was banned almost in unison from every major bank and payment processor. Last summer, video game sales platform Steam was forced to remove numerous pornographic video games by MasterCard, Visa, and Stripe. There are many such examples where it seems likely or obvious that several major financial institutions, instead of behaving as independent competitors, instead colluded together to erase content they disliked from the financial system, presenting united fronts that gave their targets essentially no viable options for moving money unless they bowed to the will of this cartel. That isn't a free market. It's technically private entities behaving as though they are a government regulator. And like with "The Twitter Files", it's highly likely that if someday their records were brought to light, a great deal of illegal or dubiously legal cooperation would be found between them and domestic or foreign state actors using private parties to launder censorship around the first amendment. Removing the "reputational risk" standard also in itself protects the reputations of financial institutions, as they would then be able to honestly say that their hands were tied and they cannot be faulted for what disfavored people may use their services, as they are legally bound to neutrality, just as many businesses pressured to segregate in the twilight years of Jim Crow were ultimately happy the Civil Rights Act passed and took the decision out of their hands, allowing them to do business with all and thus not leave money on the table, and simply tell pressure groups that the law was the law and there was nothing they could do. Please put a stop to the reputational risk standard and all forms of debanking and control of digital commerce by busybody middlemen.