Ladies and Gentlemen:
The Bank Policy Institute[1] appreciates the Board of Governors of the Federal Reserve System’s
recent efforts to promote transparency regarding access to Federal Reserve master accounts and services, including the adoption of the Board’s final Guidelines for Evaluating Account and Services Requests[2] in August that establish a transparent, risk-based, and consistent set of factors for Reserve Banks to use in reviewing applications for Federal Reserve Bank accounts and/or financial services, and the more recent proposed amendments to those Guidelines, under which the Board proposed to provide for periodic publication of a list of federally-insured and uninsured depository institutions that have access to Reserve Bank accounts and services.[3]
However, after the Board issued its most recent proposal, the National Defense Authorization
Act was signed into law on December 23, 2022. Section 5708 in Title LVII of that law provides the
following:
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[1]The Bank Policy Institute is a nonpartisan public policy, research, and advocacy group, representing the nation’s leading banks and their customers. Our members include universal banks, regional banks, and the major foreign banks doing business in the U.S. Collectively, they employ almost two million Americans, make nearly half of the nation’s bank-originated small business loans, and are an engine for financial innovation and economic growth.
[2] Board of Governors of the Federal Reserve System, Guidelines for Evaluating Account and Services Requests, Final guidance, 87 Fed. Reg. 51099 (Aug. 19, 2022), available at: https://www.govinfo.gov/content/pkg/FR-2022- 08-19/pdf/2022-17885.pdf.
[3] Board of Governors of the Federal Reserve System, Guidelines for Evaluating Account and Services Requests, Notice and request for comment, 87 Fed. Reg. 68691 (Nov. 16, 2022), available at: https://www.govinfo.gov/content/pkg/FR-2022-11-16/pdf/2022-24929.pdf.
