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Federal Reserve: Master Accounts and the
Payment System
October 12, 2022
Financial technology (fintech) has led to innovation in retail payments by both traditional banks and
fintech firms. Although these fintech firms do not provide traditional banking services, some have
sought-and some have been granted-state or federal bank charters. For payment firms, a major
motivation for seeking a bank charter is to obtain a Federal Reserve (Fed) master account to access
wholesale payment systems and related Fed payment services (but not the Fed's discount window)
without needing a bank to act as an intermediary. More recently, cryptocurrency firms with state bank
charters have applied for master accounts in order to more seamlessly transact between crypto and official
currency.
Banks hold most of their reserves in master accounts at the Fed. Reserves are assets held as liquid cash
balances, as opposed to funds invested in loans or securities. Banks were subject to minimum reserve
requirements until 2020, when the Fed removed them. All types of payments between end users (such as
customers and merchants) with different banks using different payment systems can be completed
because master accounts are connected to each other at the Fed. Customer payments are aggregated and
netted by banks, which can then debit and credit each other's master accounts through wholesale payment
systems, where they are cleared and settled.
Institutions must apply to the Fed to receive master accounts. These applications have typically been
approved quickly for traditional banks, but some nontraditional applicants have reportedly faced delays,
causing consternation. The growing number of nontraditional applicants has raised policy questions about
who is and who should be eligible for master accounts (under existing law or through legislation), how
transparent the application process should be, and what safeguards the Fed should impose on firms with
master accounts.
Emblematic of this debate, two recent examples have attracted policy interest. First, the master account
application of Reserve Trust, a fintech payment company with a state trust bank charter, was raised at the
confirmation hearing for Fed nominee Sarah Bloom Raskin, who had previously served on Reserve
Trust's board of directors. Second, Custodia Bank, a Wyoming state-chartered special purpose bank
specializing in cryptocurrency services, has sued the Fed for delaying a decision on its October 2020
master account application. Other examples of controversial applications include a public bank, a narrow
bank, and a bank to provide services to cannabis businesses.
Congressional Research Service
https://crsreports. congress.gov
IN12031
CRS INSIGHT
Prepared for Members and
Committees of Congress

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