ABA comment letter writing guide: Board of Governors Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests

Board of Governors Proposal to allow limited access to the Federal Reserve Payment System

ABA urges all bankers to comment in response to the Board of Governors proposal that would allow limited access to the Federal Reserve Payment System.

Why Public Comments Are Important

The Board’s proposal would create a limited-purpose Federal Reserve “Payment Account” that provides direct access to Fed payment services without the broader privileges associated with a master account. The proposal seeks to encourage payments innovation while maintaining strong safeguards, and it would not alter existing statutory eligibility requirements for Federal Reserve access. 

ABA strongly recommends that bankers express their concerns to the Board of Governors about this proposal. Individual bank comments, particularly those that share information and anecdotes about the impact of a proposal on the bank’s customers, are very persuasive. To assist you with your letter, we offer the following outline based on ABA’s response. The outline includes points you may wish to include in your letter as well as suggestions for bank-specific information.

Comments due: Monday, July 27, 2026

Issue Background

On May 20, 2026, the Board of Governors of the Federal Reserve System issued a proposal to establish a new type of Federal Reserve account called a “Payment Account.” The proposal is intended to provide certain legally eligible financial institutions with direct access to Federal Reserve payment services for the limited purpose of clearing and settling payments, while imposing safeguards designed to mitigate risks to the Federal Reserve and the broader payment system. 

The Board notes that the payments ecosystem is evolving rapidly and that an increasing number of institutions with non-traditional business models are seeking direct access to Federal Reserve payment services. Many of these institutions are not federally insured and may not require the full functionality of a traditional Federal Reserve master account. The proposal seeks to support payments innovation while preserving safety and soundness. 

A Payment Account would be a limited-purpose Federal Reserve account that allows eligible institutions to access Federal Reserve payment services to clear and settle payment transactions. It is intended to be a narrower alternative to a traditional master account. It is very important to note that the proposal does not expand legal eligibility for Federal Reserve accounts or payment services. Only institutions that are already legally eligible under existing federal law would be able to request a Payment Account. This proposal does not allow non-banks access to a Payment Account. Instead it would be an option for chartered institutions that may not hold insured deposits or participate in traditional banking activities.

Guardrails in the RFC to Mitigate Payment Account Holder Risk

  • Have access to Federal Reserve payment services for payment clearing and settlement purposes. 
  • Not earn interest on balances held at a Reserve Bank. 
  • Not have access to intraday credit or daylight overdrafts. 
  • Not have access to the discount window. 
  • Be subject to balance limits and automated controls designed to prevent overdrafts. 
  • Be expected to maintain appropriate controls to address illicit finance, AML, and sanctions risks.

Comment Letter Writing Guide

  • Go to the Board of Governors of the Federal Reserve System. At this webpage, you can attach a PDF copy of your letter or type a letter into the narrative box provided.
  • You can also email your letter to publiccomments@frb.gov. Make sure you include the docket number of the subject line
  • To review the Board’s proposal and background information, go to Press Releases on their website.
  • Submit your comment by July 27, 2026.

Keep in mind the following as you draft your letter:

  • Pick and choose from the themes below; it is not necessary to comment on each issue. In fact, choosing one item to comment on and writing a two to three paragraph letter is acceptable and effective.
  • Provide specific examples of how the proposal will impact your bank.

Sample Comment Letter Outline

[Insert Date], 2026

Benjamin W. McDonough Secretary
Board of Governors of the Federal Reserve System
20th Street and Constitution Avenue NW
Washington, DC 20551

Re: Proposed Revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests; Regulation A: Extensions of Credit by Federal Reserve Banks; and, Regulation D: Reserve Requirements of Depository Institutions (Docket Nos.: OP-1878; R-1892; R-1893)

Dear Mr. McDonough:

I. Introduction
  • Introduce your bank [Asset size, footprint, primary regulator, business model, etc….]
  • Thank the Board for the opportunity comment
  • Explain the role payments play in your bank and the importance of a safe and secure payment system.

Key Issues You May Wish to Address:

[Insert bank-specific examples where appropriate]

II. Key Points

Possible points to include:

  • A safe and secure payment system is essential for the U.S. economy.
  • The Board should retain all the guardrails included in the RFC including:
    • Restricting access only to chartered financial institutions.
    • Prohibiting access to the discount window.
    • Prohibiting earning interest on overnight balances.
    • Prohibiting daylight overdrafts (all payments must be prefunded).
    • Prohibiting access to FedACH because that could lead to overdrafts.
    • Be subject to closing balance limit caps.
  • In addition to those guardrails, the Board should:
    • Require that all Payment Account holders be subject to direct federal banking agency supervision.
    • Establish clear public facing review criteria for applicants.
    • Further restrict nesting arrangements.
    • Develop exit or resolution procedures.
    • Prohibit Payment Account Holders from access to the National Settlement System and the Fedwire Securities Service for transfers free of payment (FOP).

Example language:

The OCC’s proposed approach to interest and yield prohibition is a constructive step, but it does not go far enough. The rule should explicitly prohibit both direct and indirect payments of interest or yield, and not merely create a test tied to narrowly defined arrangements. Sophisticated issuers can and will engineer around unclear rulemakings and enumerated examples. A flat prohibition against direct and indirect interest and yield payments, supplemented by illustrative examples closes regulatory and statutory gaps. The GENIUS Act was written to ensure stablecoins function as a means of payment and do not disintermediate bank deposits; the final rule must be drafted to enforce that intent.

III. Conclusion
  • Thank you for the opportunity to comment.
  • Signed by a senior executive at the bank.

ABA Letter for Your Reference

Please cut and paste from the ABA letter below to support the points you make in your bank’s comments. Remember, it doesn’t need to address more than a few items.

The most important points to make are:

  • The Board should not backslide on any of the proposed guardrails (no interest, no overdrafts, no ACH, etc…) and:
  •  Payment Account holders be subject to direct federal banking agency supervision.

Click to download the letter