The Federal Reserve Board, on August 15, 2022, issued final guidelines for regional Reserve Banks to use when considering applications for Federal Reserve “master accounts”—deposit accounts that enable direct access to the Federal Reserve’s payment systems and provide critical infrastructure to financial institutions operating in the United States. The final guidelines comprise a set of principles and three-tiered review framework that, according to the Board, should bring greater transparency and consistency to the application process. 

Although the final guidelines will help to move forward the discussion around account access, the Board left key issues open. The fintech community must continue to wait for resolution as Reserve Banks and federal courts grapple with the ultimate question: What types of nontraditional financial services providers are eligible for master accounts, and on what terms?