Working Paper No. 237 July 30th, 2025 ABSTRACT This paper examines the Federal Reserve’s current financial losses—unprecedented in scale—andthe questionable accounting practices it uses to downplay their impact. It argues that the Fed’s self-defined accounting standards, particularly the creation of a “deferred asset” to mask negativeequity, obscure the fiscal consequences for the U.S. government and taxpayers. The analysisconnects today’s losses to longstanding institutional practices, notably the Fed’s flawed cost-recovery accounting for its Fedwire payment system. These issues first emerged in the late 1990sand early 2000s, when the author, then a Fed staffer, challenged the internal logic used to claimthat Fedwire guaranteed payments and still avoided subsidies. The paper includes as an appendixthe original 2002 draft, “Fedwire: A Subsidy That Fully Recovers Its Cost?”, which helped revealthe moral hazard and accounting inconsistencies that contributed to the 2008 crisis and continueto shape central bank risk and governance today. https://doi.org/10.36687/inetwp237 JEL codes: E58,E42,G28,H83,L50 Keywords:Federal Reserve, Central bank accounting, Fedwire, daylight overdrafts, Paymentsystems, financial crisis, monetary policy, financial regulation Lately the Federal Reservehas beendoing something it has never done before. It is losing lots ofmoney.These losses haveconsequences for the already-poor financial condition ofourfederalgovernment.The Fed has also beenbehaving badly while accounting for itself, employingdeceptive accounting practicesthatdownplayits deteriorating financialcondition.Deceptiveaccounting at the Fed is not a new thing,however. CurrentFedaccounting issues andmassivefinancial losseshave roots inquestionsI raisedabout Federal Reserve payment systemswhileworking at the Fed in thelate 1990s and early 2000s. A central bank does three main things, at least in the United States. It conducts monetary policy,itregulates(and supervises)banks,and it provides payment services.Monetary policy involvesbuying and selling securities and lending to bankstomanagebenchmarkinterest rates andtheoverall flow of money and credit.In the US, Congress has directed the Fed to do sowith astatutory mandate to achieve “maximum employment,” “stable prices” and “moderate long-terminterest rates.”The Federal Reservealsoregulatesand supervisesbanksand other financialinstitutionsto promotebanking stability and consumer protection. Together, the Fedadvertisesthatit conducts monetary policy and financial regulationto providea“safe, flexible and stablemonetary and financial system.” A central bank need notconduct monetary policy as well asfinancialregulation. In fact, there arestrong arguments against combining those two elements, as they can undermine the stated goalswhen conducted by the same institution.TheFedstatementthat itprovides a “safe, flexible andstable monetary and financial system” appearedatthe top of the Federal Reserve Board’swebsitebefore,during, and after themassive 2008-2009 financial crisis.It still appears theretoday, helpingus all rest easy–at least, most of us. Monetary policy and bank regulationare relatively well known.There is a third leg of the stool,however,andone that receives far less attention than it should.Banking system stabilitydependson interconnections between banks, and banks are importantly linked to one anotherthrough thethird leg of the stoolatthe Fed–its payment system services. You can put moneyintwomainbuckets. There is “money at rest,” andthere is“money inmotion.” Money at rest, much of it, is in bank accounts. Central banking and deposit insurancehelp secure afeeling of safety in cash, and our accounting principlesputcashat the top of thebalance sheet to advertise its primary liquidityrole.But these accounting practices put two verydifferent things into “cash.” There is “cash on hand” (currency, Federal Reserve Notes) and thereis “cash in bank” (bank deposits). Uninsured cash can be very risky,and many financial professionals got a reminder that cashmanagement is never to be taken for granted inthe 2023 banking crisisthat led tothe failureofSilicon Valley Bank. As “money at rest” includes bank account balances, it is also worthremembering a memorable line from a banking attorney who defined “money in the bank” as a“lawsuit in embryo.” How about “money in motion?” Wecan pay eachothermoney through banks. Banks also payeach other money, however. The Fedprovides massive wholesale payment servicesforbanksthat want tomove money to each other,on their own behalf and on behalf of their customers. The Federal Reserve’s“Fedwire” paymentsystemmovestrillions of dollars in paymentsbetween banksevery day. Itis popular for a few reasons,including the fact that the Fedhasguaranteedevery payment that it processes to the receiving bank–even if the sending bankdidn’t have the money in its reserve account at the Fed when it sent the payment. These“unfunded” payments can lead to “dayl