Removing Barriers Blog

CUNA Comment Letter filed w/Fed re Proposed Account Access Guidelines
Posted July 12, 2021 by CUNA Advocacy

Today, we filed a comment letter with the Fed in response to an RFC on proposed guidelines (Guidelines) to evaluate requests for accounts and services at Federal Reserve Banks. 

We support the Fed’s effort to establish clear and consistent guidelines to evaluate requests for master account access to Reserve Bank accounts and services. However, the proposed Guidelines do not address how the Reserve Banks would ensure that new applicants that are not subject to the rigorous regulations and supervision in place for federally-insured depository institutions or privately-insured state chartered credit unions would demonstrate adequate standards ensuring the safe operation of the payments system. 

The current system for determining eligibility for access to Reserve Bank accounts and services has worked well, but with the ever-evolving financial services marketplace financial service providers other than credit unions and banks will likely seek access. Some of these new entrants will employ novel business models that rely on new technologies that may pose unique risks to the payments system. It is also likely that banks and credit unions will adopt new technologies making it important that the Fed’s Guidelines decouple novel business models from new products and address the risk for each individually. Without proper safeguards in place either could raise risks to all participants in the payments system.

The letter offers a number of specific suggestions on how the Fed can improve the proposed Guidelines.