@PeterContiBrown Peter, as a US Federal Reserve expert, wanted to ask you a question about negative interest rates. Do you think the FRA as currently written provides a legal basis for implementing them?
Looking at section 11 in particular, the language doesn't seem to provide much room. Hard to see how "balances may ... receive earnings to be paid by the Fed" could be reasonably interpreted as "balances may ... incur interest expense to be paid to the Fed." 
Was thinking maybe they could use Section 11A to impose a fee for the service of holding excess reserves, but fees for services have to match costs actually incurred.
Similar language in other places--seems to be a general constraint that fees equal expenses.
Maybe could argue that in an environment where the true economic rate of interest is negative, holding balances at any rate less than that rate creates an effective expense for the Fed, but that would seem really squirrely and unpersuasive.
As someone close to these matters, interested in your view on the legality itself and on the Fed's likely view/approach to the legality. On my read, congress would need to amend, which is significant bc many mkt participants are under impression would be as easy as any other cut.
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