ABA and CBA Letter to the Board on the Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests

Dear Mr. McDonough:

The American Bankers Association (ABA) and the Consumer Bankers Association (CBA) appreciate the opportunity to comment on the Board of Governors of the Federal Reserve System’s Request for Comment (RFC) on Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests; Regulation A: Extensions of Credit by Federal Reserve Banks; Regulation D: Reserve Requirements of Depository Institutions. Our 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 moves from a prototype concept to a formal policy and regulatory framework, careful design and robust, enforceable 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, no access to the discount window, and only access to services for which the Federal Reserve can limit credit risk. We agree 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 activity while preserving systemic resilience. At the same time, the diverse nature of potential applicants—including uninsured entities and firms operating under non-uniform charters or evolving regulatory regimes—poses unique challenges. These attributes argue strongly for a graduated approach that proceeds only as quickly as safety and soundness allow, and that places ongoing accountability for risk management and compliance on both the applicant and, where supervisory gaps exist, on the Federal Reserve as a condition of access. ABA made similar comments regarding these and other issues in this letter in its prior response to the Board’s Request for Information (RFI) on the Payment Account Prototype issued in December 2025.

Download the comment letter to read the full text.