Anchorage Digital, the parent company of the first federally chartered digital asset bank in the United States, publicly stated on the 29th that the Federal Reserve Board’s proposed “Payment Account” framework, introduced in May, would not serve as a practical substitute for traditional master accounts. In a comment letter submitted to the Fed, the firm expressed support for the initiative to modernize access to the payment system but highlighted multiple structural constraints that pose real-world operational barriers.
The Fed’s proposal would create a new account category limited to payment and settlement purposes for certain financial institutions eligible to use accounts and payment services under the Federal Reserve Act. Eligible institutions would gain access to core services such as the Fedwire large-value funds transfer system and the FedNow instant payment service, but would not receive intraday credit, access to the discount window, or interest on balances held at the Federal Reserve.
Anchorage Digital took particular issue with the exclusion from FedACH, the automated clearing house system that processes interbank electronic funds transfers. FedACH underpins routine transactions including payroll deposits, bill payments, and business-to-business transfers. Without access to it, Payment Account holders would remain dependent on intermediary banks for indirect fund transfers. “The foundational benefit of direct access to payment infrastructure is significantly undermined,” the firm stated in its letter.
The firm also highlighted the operational burden created by balance restrictions. While no cap applies during the business day, end-of-day balances would be subject to limits set by each regional Federal Reserve Bank, capped at a maximum of $1 billion. Financial institutions holding funds exceeding that threshold would need to sweep excess balances into separate accounts at the close of each business day, creating operational inefficiencies.
Anchorage Digital further argued that the Fed should not use the presence or absence of FDIC deposit insurance as a proxy for risk assessment when reviewing Payment Account applications. Instead, the firm called for evaluation categories based on each institution’s substantive regulatory status, including whether it is supervised by the Office of the Comptroller of the Currency (OCC) and the scope of its authorized activities. Since many crypto-related financial institutions are not covered by FDIC deposit insurance, the current review framework could result in their being classified under excessively high-risk categories.
The Fed’s proposal has drawn comment letters from crypto industry groups, the banking sector, and members of Congress. Across the industry, the framework is broadly viewed as a step forward in granting emerging financial institutions—which often struggle to obtain master accounts—a degree of payment system access. However, a growing consensus echoes Anchorage Digital’s view: the accumulation of restrictions, including limited FedACH access, balance caps, and the absence of interest payments, means the framework cannot function as a meaningful substitute for a master account.
Anchorage Digital’s comment letter underscores a broader reality: as crypto-native financial institutions seek direct participation in U.S. payment infrastructure, the design of regulatory frameworks remains anchored to the traditional banking model. The Fed is expected to draft final rules based on the feedback received, with the key question being how far it will go in addressing practical demands such as expanding FedACH access and relaxing balance restrictions.