American Payment Network Act¶

Implementation Timeline¶

Published February 2026¶

Based on Rev 3.7 of the American Payment Network Act

Timeline Overview¶

The American Payment Network Act (APNA), hereafter referred to as "the Act," employs a digital-first implementation strategy that prioritizes rapid nationwide access through existing infrastructure before physical buildout. The five-year implementation horizon balances urgency with operational realism. The self-capitalizing funding model ensures implementation proceeds on schedule regardless of annual appropriations cycles.

Phase Summary¶

Phase	Timeline	Focus
Foundation	Months 1-12	Regulatory framework, ODPI standup, technical architecture, initial Fund capitalization
Pilot	Months 13-18	Five-state pilot program launch
Expansion	Months 19-36	USPS partnerships, digital rollout expansion
Consolidation	Months 37-60	Nationwide digital coverage, targeted physical buildout
Maturation	Year 6+	Ongoing maintenance, accessibility improvements, borrowing repayment completion

Key Milestones¶

Milestone	Deadline
American Payment Network Fund established	Upon enactment
Initial Treasury borrowing drawdown	Months 1-6
Joint Treasury-Fed operating regulations issued	12 months
Pilot programs operational (5 states)	18 months
Minor account regulations finalized	18 months
USPS partnership agreements executed	24 months
Initial USPS access points operational	36 months
Nationwide digital rollout complete	60 months
Full borrowing repayment	Within 15 years

Effective Date Architecture¶

Upon Enactment¶

The following take effect immediately:

Establishment of the American Payment Network within Treasury (Section 4(a))
Authorization for Office of Digital Payment Infrastructure (Section 4(b))
Advisory Board authorization (Section 4(b))
General authority for Treasury to issue participation standards (Section 4(e))
Authorization for USPS partnership negotiations (Section 4(d))
State and local partnership authorization (Section 7)
Establishment of the American Payment Network Fund (Section 8(a))
Treasury borrowing authority activated -- up to $15 billion available without further appropriation (Section 8(b))
Emergency operational authority established (Section 8(h))

Within 12 Months¶

Joint operating regulations issued by Treasury Secretary and Federal Reserve Chair (Section 6)
These regulations establish the foundational technical and operational standards for APN
Transaction fee schedule established by Secretary in consultation with Federal Reserve (Section 8(d))

Within 18 Months¶

Pilot programs operational in at least five states representing diverse geographies and demographics (Section 9)
Minor account regulations finalized by Treasury in consultation with HHS, ACF, and state agencies (Section 4A(f))

Within 24 Months¶

USPS partnership agreements executed (Section 9)
These agreements establish compensation structures, service standards, and facility requirements
Compensation funded from American Payment Network Fund

Within 36 Months¶

Initial USPS access points operational (Section 9)
Priority locations: Banking Deserts, rural communities, low-income urban neighborhoods

Within 60 Months¶

Nationwide digital rollout complete (Section 9)
90% population proximity standard achieved for digital or in-person access (Section 5(d))
Network generating sufficient revenue to cover operations and debt service

Ongoing¶

Annual progress reports to Congress (Section 9)
Quarterly public reports on network metrics (Section 10)
Annual Fund status reports (Section 8(g))
GAO audits every three years, including Fund management assessment (Section 10)
Biennial review of minor account regulations (Section 4A(f))

Long-Term (Years 6-15)¶

Borrowing repayment continues from Fund revenues
Full repayment required within 15 years of initial borrowing
Post-repayment: six-month operating reserve maintained
Excess revenues may fund fee reductions, service expansion, or General Fund transfers

Capitalization and Funding Sequencing¶

The self-capitalizing funding model is integral to implementation success. Treasury borrowing authority eliminates dependence on annual appropriations, ensuring implementation proceeds on schedule.

Funding Flow¶

Enactment
    |
    +---> Fund Established (Immediate)
    |         |
    |         +---> Initial Borrowing Drawdown (Months 1-6)
    |                   |
    |                   +---> ODPI Standup Funded
    |                   +---> Technical Architecture Contracts
    |                   +---> Pilot Program Preparation
    |
    +---> Revenue Streams Activate (Month 18+)
              |
              +---> Transaction Fees (as volume grows)
              +---> Interest Earnings (settlement balances)
              +---> Certification Fees (APN Agent onboarding)
              +---> State Cost-Sharing (voluntary integrations)
              |
              +---> Self-Sustaining Operations (Year 3+)
                        |
                        +---> Debt Service Priority
                        +---> Full Repayment (by Year 15)

Borrowing Strategy¶

Initial Drawdown (Year 1): Draw only amounts necessary for ODPI standup, technical architecture, and pilot preparation. Estimated: $2-4 billion.

Expansion Phase (Years 2-3): Additional drawdowns as needed for USPS partnerships, digital scaling, and nationwide expansion. Estimated: $3-6 billion cumulative.

Consolidation Phase (Years 4-5): Final drawdowns for physical infrastructure gaps and full capacity. Estimated: $5-10 billion cumulative.

Contingency Reserve: Remaining borrowing authority ($5-10 billion) held in reserve for unforeseen costs.

Congressional Notification Triggers¶

50% threshold ($7.5 billion): Report on expenditures, cost projections, variance explanation
75% threshold ($11.25 billion): Assessment of additional authority needs, cost containment measures
180 days before exhaustion: If full $15 billion insufficient, advance notice for Congressional action

Sequencing Requirements¶

Implementation follows a logical dependency chain where each phase enables the next. The self-funding model removes appropriations from the critical path.

Dependency Chain¶

Enactment
    |
    +---> Fund Establishment + Initial Borrowing (Immediate)
    |         |
    |         +---> ODPI Standup (Months 1-6)
    |                   |
    |                   +---> Rulemaking Initiation
    |
    +---> Technical Architecture (Months 3-12)
    |         |
    |         +---> API Standards
    |         +---> Security Protocols
    |         +---> FedNow Integration Assessment
    |
    +---> Joint Treasury-Fed Regulations (Month 12)
              |
              +---> APN Agent Certification Standards
              |         |
              |         +---> Agent Onboarding (Months 12-18)
              |
              +---> Transaction Fee Schedule (Month 12)
              |
              +---> Pilot Program Launch (Month 18)
                        |
                        +---> Revenue Generation Begins
                        |
                        +---> Pilot Evaluation (Months 18-24)
                        |
                        +---> Nationwide Expansion (Months 24-60)

Critical Path Items¶

The following items are on the critical path -- delays here cascade throughout implementation:

Fund Establishment and Initial Borrowing (Immediate): Cannot proceed without funding authorization; self-executing upon enactment
ODPI Standup (Months 1-6): Cannot issue regulations or negotiate partnerships without administrative capacity
Joint Treasury-Fed Regulations (Month 12): Defines participation standards that APN Agents need before they can connect; also establishes fee structure
APN Agent Certification (Months 12-18): Cannot launch pilot without certified agents to provide front-end services
USPS Partnership Agreements (Month 24): Physical access strategy depends on these agreements; delays push back cash access in underserved areas

Note: Appropriations are NOT on the critical path. The borrowing authority ensures implementation funding is available immediately upon enactment.

Parallel Workstreams¶

The following can proceed simultaneously:

Technical architecture development and regulatory drafting
USPS partnership negotiations and pilot program operation
Minor account regulation development and general participation standards
Digital infrastructure buildout and physical site assessments
Revenue system development and Fund accounting establishment

Institutional Standup¶

New Entities¶

Office of Digital Payment Infrastructure (ODPI)

Location: Within Department of the Treasury
Function: Network administration, agent certification, compliance oversight, settlement integrity, Fund management
Staffing requirements: Technical specialists (payments systems, cybersecurity), regulatory staff, compliance officers, policy analysts, financial management staff
Estimated standup timeline: 6-12 months for core capacity; ongoing expansion as network grows
Funding: American Payment Network Fund (no appropriations dependency)

Advisory Board

Composition: Nine members representing Treasury, Federal Reserve, USPS, community financial institutions, consumer protection agencies, and public representatives
Function: Advise on standards, security, and access
Appointment process: To be determined by Treasury regulations
Meeting cadence: To be determined; quarterly minimum recommended

Treasury Node

Function: Operational division responsible for network oversight, compliance, and settlement integrity
Relationship: Operational arm of ODPI; interfaces with Federal Reserve for settlement services
Technical requirements: Real-time clearing and settlement systems, interoperability with FedNow/ACH

American Payment Network Fund

Location: Treasury of the United States
Function: Dedicated funding vehicle for all APN operations
Management: Secretary of the Treasury
Accounting: Annual reporting to Congress, GAO audit inclusion
Features: Without fiscal year limitation; available without further appropriation

Interagency Coordination¶

Treasury-Federal Reserve:

Joint rulemaking authority for operating regulations
Fed provides settlement and liquidity services
Potential integration with FedNow infrastructure
Consultation on transaction fee schedule

Treasury-USPS:

Partnership agreements for physical access points
Negotiated compensation arrangements funded from American Payment Network Fund
Staff training and facility modification coordination

Treasury-HHS/ACF:

Consultation on minor account regulations
Coordination with child welfare systems for foster youth provisions

Treasury-State Agencies:

Coordination with state banking regulators (Section 4A(f)(3))
State child welfare agency coordination for minor accounts
Voluntary integration of state payment systems (Section 7)
Cost-sharing arrangements credit revenue to Fund

Transition Provisions¶

Digital-First Transition¶

The Act does not displace existing payment infrastructure but creates an additional public option. The transition is additive rather than substitutive.

Existing Federal Payment Systems:

Direct Express (Treasury prepaid debit cards) continues during transition
Social Security direct deposit continues through existing bank relationships
Tax refund delivery continues through existing channels
APN provides additional delivery option; does not mandate migration

Existing Financial Institutions:

Banks, credit unions, and fintechs may become APN Agents voluntarily
No requirement to connect; participation is incentivized through service fee revenue
Existing accounts remain valid; customers may maintain both traditional and Network Accounts

Phased Feature Rollout¶

Not all features need to be available at pilot launch. Recommended sequencing:

Phase 1 (Pilot):

Basic account opening and verification
Direct deposit receipt
Balance inquiry and transaction history
P2P transfers within APN
Debit card issuance

Phase 2 (Expansion):

Full APN Agent network integration
ATM network integration
SMS/USSD access for feature phones
Bill payment functionality

Phase 3 (Consolidation):

Minor accounts under Section 4A
Full USPS cash services
International transaction capabilities
Complete public access point registry

Unbanked Population Transition¶

The Unbanked Access Program (Section 5(g)) requires dedicated attention:

Alternative identity verification systems must be operational before full rollout
Community organization partnerships should be established during pilot phase
Financial literacy materials and onboarding assistance protocols developed during Phase 1
In-person onboarding capacity at USPS and APN Agents established by Phase 2

Contingencies and Flexibility¶

Built-In Flexibility¶

The Act includes several flexibility mechanisms:

Secretary Discretion:

Banking Desert definition (Section 3)
Service center location and design criteria (Section 4(d))
ATM fee reimbursement standards (Section 5(f))
Geographic coverage assessment (Section 5(f))
Alternative identity verification standards (Section 5(g))
Borrowing drawdown timing (Section 8(b))
Transaction fee adjustments within 0.05% cap (Section 8(d))

Regulatory Adjustment:

Treasury may adjust minor account transaction limits based on demonstrated responsibility (Section 4A(b))
Biennial review of minor account regulations allows ongoing refinement (Section 4A(f))
Participation standards can evolve as technology changes
Fee schedule reviewed and adjusted annually (Section 8(d))

Timeline Flexibility:

Section 9 specifies "within" deadlines rather than fixed dates, allowing acceleration where possible
Physical infrastructure (Priority Two service centers) only required "where USPS infrastructure is insufficient"
Digital coverage prioritized; physical buildout responds to demonstrated need

Fiscal Flexibility:

Borrowing drawdowns timed to actual needs, minimizing interest costs
Revenue sources diversified (transaction fees, interest, certification fees, state cost-sharing)
Excess revenues can fund fee reductions, service expansion, or General Fund transfers
Emergency operational authority ensures continuity during government disruptions

Risk Mitigation¶

Technical Risks:

FedNow integration assessment early in process (within first 12 months)
Pilot program in diverse states tests technical architecture before nationwide rollout
Multiple access channels (web, mobile, SMS, ATM, in-person) provide redundancy

Operational Risks:

USPS partnership is prioritized but not mandated; if negotiations fail, Treasury has authority to establish purpose-built service centers
Digital Agents can satisfy cash access through ATM networks or retail partnerships, not solely USPS
Voluntary APN Agent participation means network can launch with willing institutions

Fiscal Risks:

Appropriations risk eliminated: Self-funding model with Treasury borrowing authority ensures implementation is not subject to annual appropriations, continuing resolutions, or government shutdowns
Emergency continuity: Section 8(h) authorizes continued operations from Fund balances during government disruptions
Cost overrun transparency: Borrowing threshold notifications provide early warning of budget issues
Revenue shortfall protection: $15 billion cap provides contingency headroom; fee adjustments available within cap

Political Risks:

Pilot program demonstrates viability before full commitment
State partnership is voluntary, reducing federalism objections
Utility framework framing positions APN as infrastructure, not competitor to private sector
Self-funding model reduces ongoing fiscal debates

Delay Scenarios¶

If USPS Partnership Negotiations Extend Beyond 24 Months:

Digital rollout continues on schedule
Digital Agent cash access (ATM networks, retail partnerships) fills gap
Purpose-built service center authority provides alternative path
Funding unaffected -- no appropriations dependency

If Pilot Program Reveals Significant Issues:

18-month pilot window allows for iteration before expansion
Annual progress reports to Congress provide accountability
Regulations can be adjusted before nationwide rollout
Fund provides resources for course corrections

If APN Agent Participation Is Lower Than Expected:

Treasury Node can provide direct services as backstop
Service fee adjustments may improve participation incentives
USPS and purpose-built centers ensure baseline access regardless of private participation

If Revenue Generation Is Slower Than Projected:

Borrowing authority provides buffer during ramp-up
Fee adjustments within cap can improve revenue
15-year repayment timeline provides flexibility
Cost containment measures available as documented in required notifications

Resource Requirements Summary¶

All resource requirements funded from American Payment Network Fund, not annual appropriations.

Year 1 Priorities¶

Requirement	Estimated Scope	Funding Source
ODPI initial staffing	50-100 FTEs	Fund (borrowing)
Technical architecture contract	Major systems integration	Fund (borrowing)
Legal/regulatory staff for rulemaking	10-20 FTEs	Fund (borrowing)
Advisory Board establishment	9 appointments + support staff	Fund (borrowing)
Fund accounting and management systems	Financial infrastructure	Fund (borrowing)

Years 2-3 Priorities¶

Requirement	Estimated Scope	Funding Source
Pilot program operations	5 states, diverse demographics	Fund (borrowing + initial revenue)
USPS facility modifications	Priority Banking Desert locations	Fund
USPS staff training	Locations designated as APN access points	Fund
APN Agent certification processing	Hundreds to thousands of institutions	Fund (offset by certification fees)
Digital infrastructure scaling	Nationwide capacity	Fund

Years 4-5 Priorities¶

Requirement	Estimated Scope	Funding Source
Nationwide operations	Full ODPI capacity	Fund (primarily revenue)
USPS network completion	All designated access points	Fund
Purpose-built service centers	Only where USPS insufficient	Fund
Ongoing compliance monitoring	All APN Agents	Fund
Public reporting systems	Quarterly metrics publication	Fund
Debt service	Borrowing repayment	Fund (revenue priority)

Years 6-15 (Maturation)¶

Requirement	Estimated Scope	Funding Source
Ongoing operations	Steady state	Fund (revenue-sustained)
Debt service completion	Full repayment by Year 15	Fund
Reserve maintenance	6-month operating reserve	Fund
Network improvements	As needed	Fund (or excess revenue)

Implementation Success Criteria¶

Quantitative Metrics (Section 10)¶

Account uptake and activation rates
Transaction volume and types
Average transfer cost
Service availability by access channel
Cash access point distribution and coverage
Feature phone and SMS/USSD usage statistics
Security incidents and fraud prevention effectiveness
Progress toward 90% population proximity standard

Financial Metrics (Section 8(g))¶

Fund balance trajectory (growth toward sustainability)
Revenue by source (transaction fees, interest, certification, state payments)
Expenditure efficiency by category
Borrowing utilization vs. authorization
Debt service progress toward 15-year repayment
Reserve adequacy post-repayment

Qualitative Indicators¶

Unbanked household participation rates relative to baseline
Geographic equity in access point distribution
Stakeholder satisfaction (APN Agents, account holders, partner agencies)
Successful integration with American Prosperity Stability Payment (APSP) and other federal programs when enacted
Operational continuity during any government disruptions

Revision History¶

Revision 3.7 (Current) - Expanded APSP acronym to full name at first use in Qualitative Indicators section - Updated reference line to Rev 3.7

Revision 3.6 - Aligned document structure to APAI Document Production Standards Rev 1.5 - Renamed document from "Implementation Architecture" to "Implementation Timeline" per Section 3.3 naming convention - Updated header from legislative-text format to supporting document format (Published date, reference line) - Converted ALL CAPS section headings to title case per heading hierarchy standards - Removed "Prepared by" block from header; attribution moved to standard footer - Applied self-reference conventions per Section 1.7 (established "the Act" after first use) - No changes to timeline content, sequencing, resource estimates, or success criteria

Revision 3.5 - Updated to reflect self-capitalizing infrastructure model (Section 8 replacement) - Added Capitalization and Funding Sequencing section with funding flow diagram and borrowing strategy - Added Congressional notification triggers and cost containment provisions - Updated resource requirements to reflect Fund-based financing throughout - Added fiscal risk mitigation (appropriations risk eliminated, emergency continuity) - Incorporated Fund establishment, borrowing drawdown, and revenue activation into dependency chain and critical path - Updated success criteria with financial metrics (Fund balance, revenue by source, debt service progress)

📄 Download this document (opens on GitHub -- click the ⬇ download button)

Prepared by Albert Ramos for The American Policy Architecture Institute