Circle Internet Financial recently submitted a response to the Federal Reserve’s proposal to extend the operating hours of its Fedwire Funds Service and National Settlement Service to 22x7. Circle supports this expansion, as it would modernize the U.S. wholesale payments system and reduce weekend and holiday settlement risks. However, Circle raises concerns that while this expansion might improve wholesale payments, it may not address significant challenges in everyday consumer payments and could exacerbate existing risks between banking and payment sectors. Circle advocates for a comprehensive approach that includes granting non-bank payment institutions access to Federal Reserve master accounts, which could enhance payment infrastructure, reduce liquidity demands on banks, and allow banks to focus more on lending activities. Circle also highlights its own innovations, such as the USDC, which operate on a continuous basis and urges regulators to consider a more holistic and efficient restructuring of the financial sector that separates payments from traditional banking.