rules adopted in 1994 caused the number of checks processed by the Fed to fall sharply, to a low of 15.5 billion in 1995.2 Although the Fed’s processing volume rose annually between 1995 and 1999, in 1999 the Fed handled 17.1 billion checks and volume has since been declining steadily. The Monetary Control Act of 1980 requires the Federal Reserve to charge fees for providing payments services, ...