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Client Alert
The Federal Reserve Opens a Door for Fintech and Digital-Asset Firms: The May 2026 Executive Order and Payment Account Proposal
A proposed framework for limited-purpose Federal Reserve payment access.


Federal Reserve payment access may be opening to nonbank fintech and digital-asset firms.
Over two days in May 2026, the White House and the Federal Reserve took coordinated steps that could, for the first time, give nonbank payment and digital-asset firms a direct, limited channel into the central bank’s payment rails. On May 19, 2026, President Trump issued an Executive Order titled “Integrating Financial Technology Innovation Into Regulatory Frameworks” (the Order). The following day, the Board of Governors of the Federal Reserve System (the FRB) requested public comment on a proposal to create a special-purpose “Payment Account” at the Federal Reserve Banks (the Reserve Banks) (the Proposal).
Direct access to Federal Reserve accounts and services has long been the objective—and the obstacle—for fintech and crypto firms operating outside the traditional banking perimeter. The Proposal does not hand these firms a full-service master account, but it offers something many of them have been seeking: a defined, supervised path to clear and settle their own payments through the Federal Reserve. For institutions weighing U.S. market entry or expansion, the practical question is no longer whether such access exists, but whether the Payment Account’s constraints fit the business model. This alert summarizes the developments and flags what they mean for clients considering an application.
The Payment Account is built for one job: clearing and settling the holder’s own payments. Eligible institutions (those qualifying under the Federal Reserve Act or other federal statute) could access the Fedwire Funds Service, FedNow, the National Settlement Service and the Fedwire Securities Service (free transfers only), but not FedACH.
The account is defined as much by its constraints: it must be prefunded (no intraday credit), carries no discount-window access (Regulation A) and no interest (Regulation D), cannot participate in an excess balance account, and is capped at a $1 billion overnight balance (a change from the December 2025 RFI).
Holders may not act as correspondent or respondent banks, though they may settle as an intermediary. Review timelines—newly specified—45 days for Tier 1 and 90 days for Tier 2 and Tier 3 applicants—respond to long-standing complaints about open-ended processing, and the Proposal adds detailed illicit-finance terms that let a Reserve Bank condition, restrict or terminate access based on an applicant’s compliance posture.
No Investor Loss Required
The proposed Payment Account would give eligible nonbank firms a limited, supervised route into selected Federal Reserve payment services—without granting full master account access.
Two practical caveats temper the opening. First, statutory eligibility is not an entitlement: the FRB and the Reserve Banks maintain discretion to grant, deny or revoke access, and federal appellate courts—including the Second and Tenth Circuits—have agreed, with related litigation ongoing.
Second, the FRB has encouraged the Reserve Banks to pause decisions on Tier 3 master account requests while this policy work proceeds, a pause it expects to lift by December 31, 2026. The direction of travel is nonetheless clear: in March 2026, the Federal Reserve Bank of Kansas City had already approved a one-year, limited-purpose account for a digital-asset firm on terms closely tracking the Proposal—a concrete template for applicants to study.

Summary
What it means for market entrants:
For payments, fintech and digital-asset firms, the question is no longer whether Federal Reserve access exists, but whether the Payment Account fits the business.
Firms that need only to clear and settle their own payments may find it well suited; those that depend on FedACH, intraday liquidity, interest income or correspondent activity should weigh whether a master account remains the real objective, and Tier 3 applicants should plan around the pause.
In every case, a strong AML and sanctions program is now a gating diligence item, not an afterthought, and cross-border entrants should test the “other federal statute” eligibility hook before structuring their U.S. operating entity. Bandi & Associates advises clients on U.S. market entry, Federal Reserve access strategy, cross-border structuring and compliance, and on submitting comments ahead of the July 27, 2026 deadline. Please contact us to discuss how these developments affect your firm.
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