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Navigating Instant Recurring Payments:
Consumer, Business, and Financial
Institution Perspectives
Fasterpaymentscouncil.org May 2024
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Table of Contents
Introduction ....................................................................................................................................................................... 3
Key Components for Recurring Instant Payments ................................................................................................. 4
Request for Payment ................................................................................................................................................ 4
Standing Approval .................................................................................................................................................... 4
Consumers’ Concerns and Expectations .................................................................................................................. 5
Ease of Sign-Up and Use of Recurring and Subscription Payments .......................................................... 5
Support for Notifications ......................................................................................................................................... 6
Standing Approval Notification Categories ................................................................................................. 6
Additional Guidelines on Timing and Frequency ....................................................................................... 7
Ability to Make Updates and Changes to Scheduled Payments ........................................................... 7
Financial Institution Integration Support ....................................................................................................... 8
Security ......................................................................................................................................................................... 8
Merchant and Business Foundational Elements ................................................................................................. 10
Request for Payment ............................................................................................................................................. 10
Understanding Request for Payment and Instant Recurring Payments ............................................ 10
Challenges with Standing Approvals........................................................................................................... 10
Foundational Elements for Integration ....................................................................................................... 10
Platform Enhancements ................................................................................................................................... 11
Data Integration and Management .................................................................................................................. 12
Security, Fraud, and Compliance Measures ......................................................................................................... 13
Financial Institution Foundational Elements ........................................................................................................ 15
Financial Institutions Receiving RfPs ................................................................................................................. 15
Financial Institutions Originating RfPs.............................................................................................................. 16
Final Thoughts ............................................................................................................................................................... 17
Acknowledgements ..................................................................................................................................................... 18
References ......................................................................................................................................................... 19
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The Faster Payments Council Real-Time Recurring Work Group presents this needs assessment to
support instant payments, focusing on the unique attributes of recurring and subscription
payments. The team of experts rendered their collective opinions as viewed from various
stakeholders’ perspectives specifically consumers (payers), merchants/businesses (payees), and
financial institutions. This report will use the terms “merchant” and “business” interchangeably. In
some cases, the terms payer and payee will be used; consumers will typically be payers and
merchants/businesses will be payees.
Introduction
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Before diving into the foundational elements and expectations of consumers, merchants, and
financial institutions, there are a couple of key components that need to be in place for instant
payments to be a viable option for recurring payments.
Request for Payment
The Request for Payment (RfP) is one of the new features of the instant payments service. This
powerful tool is a key component for supporting instant recurring payments. Technically, the RfP is a
standardized network message ISO20022 Pain.013
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which enables a payee to make a request for an
instant payment from a potential payer through the network and to keep a record of the payment for
the payer. By using RfPs, financial institutions and other service providers can support new value-
added instant payment services for their customers.
Standing Approval
Associated with the RfP is the payer’s review and approval of the RfP. This consists of two unique
steps. First, the financial institution receiving the RfP presents the RfP to the payer for review via the
financial institutions online and/or mobile banking solution. Second, the payer approves the RfP
which initiates an instant payment credit to the payee that initially requested the RfP.
For instant payments to be a viable option for recurring payments, the RfP must allow for the creation
and use of a standing approval. A standing approval is an instruction or set of instructions a payer
uses to pre-authorize their financial institution to pay future RfPs without requiring the payer to review
and approve each RfP. These standing approvals are maintained at the payer’s financial institution
and can be revoked at any time by the payer.
References to both the RfP and standing approvals are noted throughout this assessment.
Key Components for Recurring Instant
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Payments
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While recurring payments may not represent the majority of transactions that consumers make each
day, one would be hard pressed to find individuals or households that do not utilize recurring or
subscription payments as they go about their daily lives. Recurring payments are being used for
utilities, cell service, insurance, debt payments, investment payments, entertainment, food services,
and more. The convenience factor of paying for recurring bills is supplemented by large growth in
subscriptions, which doubled between 2019-2022.
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As consumer expectations of receiving services on demand have increased, the need for better
support of instant bank payments for recurring transactions has as well. There are four key areas that
should be considered to address consumer concerns and expectations related to instant recurring
payments:
Ease of Signup and Use of Recurring and Subscription Payments
Support for Notifications
Ability to Make Changes and Updates to Scheduled Payments
Security
Ease of Sign-Up and Use of Recurring and Subscription Payments
The ease of sign-up and use of recurring and subscription payments is a critical factor in addressing
the consumer and market needs for instant recurring payments. To successfully meet these
demands, it is imperative to offer a secure and frictionless sign-up experience that resonates with
consumers. Here are the primary considerations related to the ease of use in instant recurring
payments, emphasizing the consumer's perspective.
Addressing Consumer Concerns about the Process: One key aspect of ensuring a seamless
instant recurring payment experience is addressing the concerns consumers may have about the
process and how it works. Consumer doubts about security, protections, transparency, or the
mechanics of instant recurring payments can deter adoption. To overcome these hurdles,
financial institutions and businesses need to provide comprehensive education on the concept of
instant payments. This education should clarify the benefits, security measures, protections, and
steps involved in the process, ensuring customers feel informed and confident.
Flexible Setup by Channel Preference: Consumers have diverse preferences when it comes to
managing their finances and recurring payments. While some prefer using a mobile app for
convenience, others may opt for their bank's online portal due to familiarity. To accommodate
these preferences and facilitate a smooth sign-up experience, it is essential to enable instant
recurring payment setup through multiple channels. This can include a user-friendly mobile app
or a user-centric online portal, ensuring that customers can easily set up their recurring payments
in a manner that suits them best. No one channel should be favored over another, allowing for
broad adoption.
Consumers’ Concerns and Expectations
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Support for Notifications
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Ensuring that consumers and payees can have the ability to choose which notifications they receive
will provide the greatest value to their relationship and prevents ‘notification fatigue’. This is
important because one of the added values of a recurring payment is that the consumer does not
need to worry about the payment. Receiving unwanted notifications detracts from this value. This
flexibility with notifications is kept in check by the consumer’s continuous ability to revoke specific
standing approvals at any time with their financial institution.
Additional Guidelines on Timing and Frequency
Here are some additional general guidelines to consider when determining the timing and
frequency of recurring payment notifications:
Preferred Channel: The timing and frequency of recurring payment notifications depend on
the nature of the service, the target audience, and user preferences. Standard automated
communication includes email, push notifications, SMS, social media, and phone call. Some
users might prefer one channel over another.
Preferred Time Zones: If the user base is spread across different time zones, consider
sending notifications at times that are convenient for most users.
Customization Options: Allow users to customize the timing and frequency of certain
notifications. Some users might prefer to receive all notifications, while others may want
fewer reminders.
Ability to Make Updates and Changes to Scheduled Payments
The ability to easily set up, cancel, or amend a standing approval is critical for the adoption of real-
time recurring payments. As the demand for instant and seamless transactions increases,
businesses, and consumers (the payee and payer) require the ability to modify their payment
schedules with ease, while ensuring convenience, accuracy, and security. Here are the primary
considerations:
Setting up a standing approval: One critical consideration is the implementation of dynamic
payment scheduling capabilities. One cannot fully articulate all the different possible payee
and payer interactions that could benefit from instant recurring payments. As a result, instant
recurring payments should be flexible to support varying types of recurring payment
scenarios. For example, standing approvals should have the ability to support an authorized
payment range for fluctuating bills, such as utility bills, credit payments, etc., implemented
consistently with the requirements of federal law and regulations.
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Modifications: Rather than requiring the reissuance of new standing approvals, existing
standing approvals should have the flexibility to be modified by the payer as allowed by
both their financial institution and the payee with whom they entered into the agreement.
These changes could include rescheduling, skipping, or pausing payments, as well as
adjusting installment amounts. In the cases where certain modifications are not enabled for
the payer, the payer always reserves the right to cancel the standing approval. These
features enhance convenience and customer control while addressing various situations such
as unexpected expenses, changing financial circumstances, and cash flow fluctuations.
Cancellations: Payers should have the flexibility to end a standing approval at any time with
their financial institution. In addition, payers should have the ability to end a standing
approval with the payee when cancelling their recurring service and/or payment, expanding
upon the rights provided to consumers under federal law and regulation
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. Financial
institutions should send communications to both payers and payees when standing
approvals have been canceled.
Financial Institution Integration Support
To enable easy updates and changes to standing approvals, robust integration and communication
channels are essential. It is the responsibility of the payer’s financial institution to house the
authorization details, enable the payer to make changes, and act according to the established
approval agreement.
Seamless integration of systems with instant updates is crucial to provide flexible management
options that enhance user experiences and instill confidence in the payment process. Once
authorization is provided, recurring payments need to flow as scheduled without any payer action
or additional authorization required.
Security
It is no surprise that consumers care deeply about security when making an online payment, and
setting up recurring payments and standing approvals are no exception. At the same time,
consumers do not want security measures to be distracting or cumbersome. Doing so often acts as
a barrier to commerce transactions that consumers may initially make.
In the world of instant payments there is an added responsibility to ensure that the transactions
occurring are well understood and validated by the consumer. Emphasis on a strong yet frictionless
authentication at the time a standing approval is setup helps to ensure future recurring payments
can happen seamlessly without the fear of fraud and risk to the consumer.
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What should that authentication experience accomplish and look like?
The authentication experience should validate the payer and their payment information.
Financial institution participants validate payees as legitimate and held accountable to
prevent serious cases of abuse or manipulation by payees.
The market should seriously consider a standardized directory model to help provide payers
with a consistent and secure way to authenticate themselves and their payment information.
Financial institutions should also look to standardized guidelines surrounding the consumer
authentication flow. Standardized guidelines help with consumer familiarity and adoption. These
guidelines should keep friction to a minimum to not impede commerce and to help with adoption.
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Against this backdrop of consumer needs and expectations, there are several foundational
elements that merchants, businesses, and financial institutions need to implement to support the
unique requirements of instant recurring payments.
Request for Payment
In the dynamic landscape of instant payments, RfP emerges as a pivotal tool for businesses to
engage their customers, validate payment information, and pave the way for seamless transitions
into instant recurring payments. This section explores the synergy between RfP and instant
recurring payments, addressing challenges, and proposing foundational elements for effective
integration.
Understanding Request for Payment and Instant Recurring Payments
RfP serves as a crucial intermediary step for businesses (payees) and consumers (payers), allowing
for enhanced communication and validation of payment details. Unlike traditional methods,
combining RfP and instant recurring payments fosters a direct line of communication between the
payee and the payer. This instantaneous feedback loop is instrumental in promptly addressing
payment failures and ensuring transparent communication.
However, the effectiveness of RfP is contingent upon the connectivity of both the payee’s and the
payer’s FIs to the same network, such as FedNow
®
or RTP
®
. This interoperability is essential for the
successful execution of RfP transactions.
Challenges with Standing Approvals
The concept of standing approvals, where payers pre-authorize recurring RfPs, presents a challenge
in the current instant payment landscape. As it stands, neither FedNow nor RTP supports standing
approvals. The absence of this feature requires payers to individually approve each RfP transaction,
typically through their financial institution. This procedural hurdle could become a barrier to
widespread adoption, especially in eCommerce.
Foundational Elements for Integration
Here are the foundational elements that should be incorporated into the development plan:
Strategic Banking Partnership: Collaborate with a bank proficient in API origination of RfPs to
ensure operational efficiency and an enhanced customer experience.
Expanding Reach via Multiple Platforms: Affiliation with both FedNow and RTP broadens
coverage, reaches a more extensive audience, ensures a comprehensive approach, and
helps maintain redundancy.
Merchant and Business Foundational Elements
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Seamless Integration with Existing Systems: Flawless integration of RfP origination APIs into
existing invoicing processes or ERP (Enterprise Resource Planning) systems streamlines
operations and reduces disruptions.
Data Handling and Automation: Include pertinent customer and invoice details in RfP data
fields and link to invoice data to support automation and simplify reconciliation when
payments are returned.
Coordination of Supplementary Activities: Efficiently coordinate activities such as setting
expiration timeframes in the RfP, facilitating partial payments, and accommodating
payments through alternate channels.
Round-the-Clock Processing: Provide 24x7x365 uptime to process RfP requests during non-
business hours, ensuring continuous customer satisfaction.
Embracing the capabilities of RfP within instant payment frameworks necessitates preparation and
strategic planning. By focusing on these foundational elements, businesses can enhance the
payment experience, streamline operations, and cultivate lasting customer trust in the realm of
instant recurring payments.
Platform Enhancements
A decisioning platform serves as a valuable tool for merchants and businesses, enabling the
automation of key decisions related to onboarding, registration, login, and transaction monitoring,
with a specific focus on recurring payments.
To enhance the business platform, a decisioning tool should incorporate a streamlined process for
initiating instant recurring payments. Customers (payers) should have the option to easily sign up
for instant recurring payments within the business’s website or app. This signup process should
include a comprehensive explanation of what payers are committing to and what they can expect
when they receive an RfP within their banking portal or banking app.
Maintaining a consistent banking experience for RfPs is crucial to ensure that businesses can
explain the process to payers, regardless of which financial institution they use.
During this process, payers will be required to provide their bank account and routing number, as
this information is essential for initiating payments via RfP. In the future, integration with a directory
model may allow payors to provide an alias to facilitate RfP, eliminating the need for sharing
detailed bank account information and limiting the opportunities for misdirected RfP messages.
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Furthermore, it is essential for the business to keep payers informed throughout the process. The
business should continue to send notifications to payers, notifying them that they have provided
advanced permission for the business to receive payments from the payer’s account. After the
initial setup, any changes to the recurring instant payment should be managed directly between
the payer and the business, with FIs being connected through APIs as necessary to make any
needed updates. This ensures transparency and control for payers in managing their recurring
payments and understanding their current standing with the merchant with whom they have
engaged in business. Consumers (payers) will have the option of canceling or pausing the recurring
standing approvals with their financial institution.
Data Integration and Management
The business’s data integration and management system's design should be a collaborative effort
between its internal architects and the requirements of the financial institution platform being
utilized. Typically, businesses will develop an integration with a banking partner or third-party
provider via API to facilitate instant payments. Subsequently, the business may need to adjust their
internal data flow to accommodate these instant transactions.
In the near term, developments in this area may include support for open banking and integration
with other services, such as personal financial management applications, to offer consumers a
broader range of financial services.
An important shift is necessitated in the business’s billing systems since they will no longer have
insight into the exact timing of funds receipt, as is common with recurring ACH payments. This is
offset by ‘due by’ dates, but the predictability associated with ACH debits is higher than instant
recurring payments. Instead, businesses must be prepared to accept funds 24x7x365linking the
RfP to the information needed for reconciliationand send notifications back to the payment rail as
needed.
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Financial institutions, businesses, and providers need to contemplate multiple security and
compliance considerations when developing and standing up a Request for Payment program in
the spirit of minimizing needless friction and providing as intuitive an experience as possible.
These include:
Warranty Frameworks with FedNow and RTP: Recognize that both FedNow and RTP have
laid down warranty frameworks that offer guidelines on security and compliance.
Understanding these frameworks is crucial for setting up a secure RfP program.
Initial Vetting for Recurring Payments: First-time recurring payments and standing approvals
must be fully vetted to minimize security risks. A single lapse at this stage can compromise
the integrity of future payments.
First Step Validation via Bank Portal: To enhance security, the bank portal (regardless of the
channel) must be the first point of validation for all transactions. This portal must be fortified
with the latest security measures.
RfP Reception Through Bank Portal: RfPs should also be received via the secure bank portal,
consolidating transactional activities within a verified environment.
Customer Authentication (MFA): Multi-Factor Authentication (MFA) is necessary and should
be in place to enhance customer identity verification during the setup process. Passive
authentication methods provide enhanced security.
Standing Approval Data Points: Standing approval specifications like frequency and dollar
amount tolerance can optionally be collected and/or amended after initial authentication has
been successfully completed.
Notifications and Approvals: Notifications should be provided to payers as agreed upon
between payers and payees at the time of RfP creation. Approvals should be mandatory for
any changes that exceed pre-approved thresholds.
Document Repository: The option to attach bills should be offered using a globally unique
identifier (GUID), stored in a secure document repository.
Recurring Payments: Additional authentication should only be necessary if there are changes
to the pre-approved thresholds such as frequency and dollar limits.
Tiered Verification Tools: Tiered verification tools should be used for additional security
layers and integrated into the existing bank portal for a seamless customer experience.
Security, Fraud, and Compliance Measures
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Receiver Validation: Systematic confirmation protocols should be implemented to ensure
that the receiver is legitimate and the intended recipient of the payment.
Instant Fraud and Sanction Screening: These activities should be performed in real-time to
align the timing of mitigation efforts and fraud risk.
Security Standard Alignment: Security procedures should align with industry standards for
payments authentication. Notable standards bodies include EMVCo for card-based
payments, FIDO for biometric authentication, FDX for data exchange, and W3C for web-
based interactions.
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Financial Institutions Receiving RfPs
Enabling consumer and business customers to receive and respond to an instant payment RfP for
recurring payments can dramatically improve a financial institution's value proposition to both
existing and prospective customers. To successfully offer this type of program, there are several key
elements that a financial institution will need to address:
Digital/Mobile Infrastructure: The financial institution’s digital and mobile infrastructure
serves as the platform where payers will receive and respond to payment requests. Financial
institutions need to prioritize creating a user-friendly interface, frictionless user experience
design, and backend architecture to provide clients with the necessary customer experience
and enable the program to scale as the user base grows. FIs should consider investing in
API integrations to enable seamless integrations into other financial systems and databases.
Standing Approvals: Recurring payments represent a significant percentage of bill
payments. One method for accommodating this in an RfP infrastructure is supporting
standing approvals. Standing approvals enable automated responses to recurrent RfPs, thus
reducing the need for payers to manually respond to every RfP. A successful standing
approval program will need to accommodate these via inclusion of a mechanism enabling
payers to set up, manage, or stop standing approvals.
Dispute Processing Mechanism: While instant payments are irrevocable and will reduce
disputes and returns, required consumer protections and RfP warranty guidelines require FIs
to maintain a dispute resolution process. This process should be as straightforward as
possible, enabling customers to raise concerns easily and receive timely resolution.
Included in this process should be an auditable trail for each transaction and dispute.
Fraud Prevention, Detection, and Mitigation: Given the immediate nature of instant
payments, fraud prevention measures need to be robust to mitigate instances of customers
authorizing invalid RfPs. Best practices for FIs receiving RfPs include strong customer
authentication, real-time monitoring, and alerts, among other capabilities.
Linked Invoice Capability: A significant value-add would be the ability to present a linked
invoice with each RfP. This makes it easier for consumer and business customers to manage
their finances. This could involve API integrations with popular invoicing and accounting
software.
Compliance with Network Rules Governing Receipt of RfPs: FIs receiving RfPs need to
ensure that they conform with the FedNow and RTP rulesets, which may differ slightly.
Financial Institution Foundational Elements
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Financial Institutions Originating RfPs
Enabling business customers to originate RfPs that support recurring payments on an instant
payment network will become a strategic necessity for financial institutions as instant payment
adoption grows in the United States. To successfully offer this capability, financial institutions need
to contemplate implementation of the following:
Capabilities to Originate an RfP with Reconciliation Data: At the outset, the infrastructure
should allow corporate customers to originate an RfP seamlessly, along with data needed for
automated reconciliation. Fields should allow for the inclusion of purchase order numbers,
invoice numbers, or other identifiers that facilitate auto-matching and reconciliation on the
payee's end.
Match Process: The system should also have a robust matching process that aligns inbound
credits with originated RfPs. Automated algorithms can ensure that payments are accurately
credited and can be easily reconciled.
Processes to Assure RfP Validity: In order to minimize liability exposure from originating
invalid RfPs onto an instant payment network, financial institutions need to ensure that there
are strong processes in place to confirm the validity of originated RfPs in compliance with
RfP warranty requirements. This could include multi-factor authentication, digital signatures,
or even smart contracts that validate the RfP before it gets originated onto the network.
KYCs (Know Your Customer) of businesses that will be enabled to originate RfPs will be the
strongest way to assure validity.
AML, Sanctions, KYC Screening: Regulatory compliance with Anti-Money Laundering,
Sanctions, and Know Your Customer requirements will apply to both inbound RfPs as well as
the corresponding instant payment credits.
Fraud Prevention, Detection, and Mitigation: Given the real-time nature of instant payments,
fraud prevention measures need to be robust to mitigate instances of customers originating
invalid RfPs. Best practices for FIs originating RfPs include instant cross-channel monitoring
and analytics to identify suspicious patterns, as well as a proactive mitigation strategy that
can flag and isolate potential fraud before RfPs get originated onto the network.
Ability to Link Invoice to RfP: The ability to present a linked invoice with each RfP as
originators to ensure that customers have the necessary information to authorize a payment
in a seamless fashion would be a significant value-add.
Compliance with Network Rules Governing Origination of RfPs: Both the FedNow and RTP
networks have rules governing RfPs. Any given RfP for instant recurring payments will have
to conform with at least one of these rulesets, if not both, depending on which network is
being used to initiate the RfP. As these services mature, rules may change, so FIs will need
to ensure that they track developments in this space.
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Final Thoughts
This needs assessment by the Faster Payments Council Real-Time Recurring Work Group serves as
a comprehensive guide for navigating the intricate landscape of instant payments, with a particular
emphasis on recurring and subscription transactions. By bringing together the perspectives of
consumers, businesses, and financial institutions, the document illuminates the key components
essential for the successful implementation of instant recurring payments. The work group's
strategic insights underscore the critical role of features such as the Request for Payment and
standing approval, providing a robust foundation for seamless and instant secure transactions.
Moreover, this report addresses the multifaceted concerns and expectations of consumers, delving
into areas such as user-friendly sign-up processes, notification strategies, flexibility in managing
scheduled payments, and the imperative need for stringent yet user-friendly security measures.
As businesses, financial institutions, and stakeholders embrace the principles outlined in this needs
assessment, the path toward widespread adoption of instant recurring payments becomes clearer.
The focus on collaborative integration, education, and the establishment of standardized practices
underscores the commitment to creating a secure, frictionless, and efficient ecosystem. By
prioritizing the foundational elements discussed in this report, stakeholders are not only equipped
to meet the evolving demands of today's consumers but are also poised to foster innovation and
trust in the dynamic realm of instant payments.
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Acknowledgements
Real-Time Recurring Work Group
Thank you to the members of the FPC Real-Time Recurring Work Group (RTRWG), sponsored by
BNY Mellon, who contributed to this report.
RTRWG Leadership & WG Contributors
Josh Karoly (Chair), Netflix Inc.
Andrew Gómez (Vice Chair), Lipis Advisors
Maria Arminio (WG Facilitator), Avenue B Consulting, Inc.
Dana Woller, BOK Financial
Chris Wachowicz, Boku, Inc.
Will Grace, DeNovo Treasury, LLC
Tara Campbell, GBank
Jamie Gardiner, Netflix Inc.
Erica Burris, Sionic Mobile Corporation
Dean Nolan, Strategic Resource Management Inc. (SRM)
Ross McFerrin, Trustly, Inc.
Kimberly Stachak, UMACHA
Todd Harbison, Paycision LLC
Arlene Vogel, The Central Trust Bank
About the Real-Time Recurring Work Group
The FPC Real-Time Recurring Work Group promotes the development and adoption of real-time
recurring payment solutions for business end users and financial institutions.
About the U.S. Faster Payments Council
The U.S. Faster Payments Council (FPC) is an industry-led membership organization whose vision is
a world-class payment system where Americans can safely and securely pay anyone, anywhere, at
any time and with near-immediate funds availability. By design, the FPC encourages a diverse range
of perspectives and is open to all U.S. stakeholders.
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References
[1] Faster Payments Council. (n.d.). Glossary of Terms. Retrieved April 24, 2024, from https://fasterpaymentscouncil.org/Glossary-of-
Terms. Instant (AKA Immediate/Real-time) Payments. An electronic payment solution available 24/7/365, resulting in the immediate
interbank clearing of the transaction and crediting of the payee’s account with confirmation to the payer within seconds of payment
initiation.
[2] ISO 20022. (n.d.). Best Practices: Linking Request for Payment (pain.013) message to Customer Credit Transfer (pacs.008) in ISO
20022. Retrieved April 24, 2024, from https://www.iso20022.org/sites/default/files/2020-
11/RTPG_BestPractices_Linking_Request_for_Payment_to%20Customer_Credit_Transfer_November2020.pdf.
[3] Feger, A. (2022, December 14). The state of subscriptions in 5 charts. EMARKETER.
https://www.insiderintelligence.com/content/state-of-subscriptions-5-charts.
[4] CFPB. (n.d.). § 1005.10 Preauthorized transfers. Retrieved April 24, 2024, from https://www.consumerfinance.gov/rules-
policy/regulations/1005/10/.
[5] eCFR. (n.d.). Code of Federal Regulations. Retrieved April 24, 2024, from https://www.ecfr.gov/current/title-12/chapter-X/part-
1005.