Letter on the RFI re: Reserve Bank Payment Account Prototype

Dear Mr. McDonough:

The American Bankers Association (ABA) appreciates the opportunity to comment on the Board of Governors of the Federal Reserve System's Request for Information (RFI) on Payment Account prototypes. ABA’s members share the Board's commitment to a safe, resilient, and innovative U.S. payments system. We commend the Board for approaching this proposal with a risk-based lens and for recognizing that full-service Master Accounts are neither necessary nor suitable for all potential applicants. Because the proposal concerns nascent access models and may extend limited Federal Reserve account services to entities with varying supervisory profiles and emerging business models, careful design and robust risk mitigants are essential to uphold the integrity of the payments system and to protect the public interest.

I. Overview and Executive Summary

The Payment Account is premised on: limited functionality, no interest earned on balances, no overdrafts or daylight credit, and no access to the discount window. ABA agrees with the Board's underlying premise that this design, if implemented with additional guardrails and direct federal supervision, would provide a measured pathway for eligible institutions to engage in payment activities while preserving systemic resilience.

Download the comment letter to read the full text.