BA Responds to the Board of Governors of the Federal Reserve System’s Request for Comment

Yesterday, the Blockchain Association submitted a letter in response to the Federal Reserve’s request for comment on the establishment of guidelines for the review of banks’ requests for access to Fed master accounts and related services.

The BA welcomes the Fed’s effort to establish a principles-based framework for the review of access requests. Providing financial institutions of all varieties the regulatory certainty, the flexible framework, and the oversight associated with master account access will allow the U.S. banking system to evolve and capitalize on technology and innovation to deliver better products and services, to operate more efficiently, and to reduce risk in the system.

While a positive step forward, the Association argues in its letter that additional considerations should be incorporated into the guidelines.

First, the Association recommends that the application of the proposed guidelines should be tailored to reflect the unique activities and risk profiles of banks seeking access to master accounts. Not all state- and federally-chartered financial institutions present the same level of risk to the Federal Reserve System and the banking system more broadly.

Second, the Association believes that the proposed guidelines should include a set timeline for the review of access requests to give banks some certainty that requests do not languish indefinitely.

Finally, the BA recommends that the Fed consider incorporating language that accounts for the potential creation of additional novel charters at the state and federal levels. While it is not certain whether new charters will be created and issued, a future-focused framework for the review of access requests will prevent them from becoming quickly obsolete.

The Blockchain Association appreciates the opportunity to provide comments on the Fed’s proposed guidelines. The BA and its members stand ready and eager to work with the Fed as it responds to innovation in financial services while safeguarding the safety and soundness of the U.S. banking system.

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