The Federal Reserve controls master account access to payment services like Fedwire and ACH, with 2022 guidelines creating a three tier review for insured banks, uninsured but supervised institutions, and novel charters. A Congressional Research Service report describes a skinny master account concept that would grant limited services to certain nonbanks under strict limits and collateral. Courts have upheld the Fed’s discretion in access decisions, including in the Custodia Bank case. FedNow launched in 2023 and RTP continues to grow, giving operators more connectivity options. For founders, direct access could cut costs and counterparty risk but would require strong compliance and could face caps and collateral. Congress may consider legislation or policy to define skinny accounts, and Reserve Banks would implement procedures if adopted.
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