"The solution has been described in detail. There are a few concerns related to dependencies and assumptions described in the proposal. The first dependency is that the Federal Reserve Bank will authorize MMC to open and maintain Federal Reserve accounts. These accounts will be instrumental to supporting settlement as designed.
Alternatively, MoMo may become a chartered DI (depository institution). It will be the Federal Reserve’s decision whether to support this option. In a third option, the MoMo entity would be established by new federal legislation to enable the MoMo system.
Without accounts at the Federal Reserve, the potential risks may make the solution unviable.
The solution’s success also relies on building out a large agent network (450,000 locations in five years). This network will be required to support unbanked or underbanked end-users. There are concerns about the capability of these agents to authorize end-users when they enroll and as they deposit and withdraw funds to and from the MoMo system. Training this large network, as well as monitoring and managing their performance, may be challenging."