On August 15, 2022, the Federal Reserve Board issued guidelines for how requests by fintech and other firms for access to so-called "master accounts" and other financial services at Federal Reserve Banks will be evaluated.
The guidelines apply a "tiered" review framework that varies the level of due diligence and scrutiny that Reserve Banks will apply to different types of institutions. In general, requests by federally-insured institutions should be reviewed in a fairly straightforward manner, while requests from non-federally-insured institutions may require more extensive due diligence.
The issue of master account access has been a controversial one in the last year. While the new guidelines are another item checked off the Fed's "to do list," they do not signify that Reserve Banks will move swiftly or necessarily favorably on applications by fintechs.
