The American Fintech Council (AFC) has submitted a formal letter to the Federal Reserve in support of the central bank’s proposed Payment Account framework, while calling for a series of structural improvements to how the framework is designed and implemented.
The letter responds to the Fed’s proposed revisions to its Policy on Payment System Risk and its Guidelines for Account and Services Requests, both of which govern how non-bank institutions access core payment infrastructure.
The AFC, which describes itself as the largest US trade association representing fintech companies and innovative banks, argued that the proposed framework is a meaningful step toward modernising access to Fed payment rails. Its recommendations focus on three areas: clearer eligibility standards, proportionate operational safeguards, and co-ordination across federal regulators to avoid duplicative compliance requirements.
What the AFC is asking for
At the core of the AFC’s submission is a request for objective, transparent eligibility criteria that give institutions regulatory certainty before committing to the compliance overhead a Payment Account would entail. The association also called for the framework to be principles-based rather than prescriptive, arguing that a rules-heavy approach risks becoming outdated as payment technology evolves.
Phil Goldfeder, chief executive of the AFC, said the framework “can promote competition, improve payment efficiency, and support responsible innovation while preserving the integrity of the Federal Reserve System.” Ian P. Moloney, the AFC’s chief policy officer, added that long-term effectiveness would depend on “proportionate supervision, regulatory consistency, and long-term adaptability.”
The letter further urged the Fed to build implementation on existing supervisory practices rather than constructing a parallel compliance architecture, and to commit to periodic reviews of the framework as payment technologies and market structures shift.
Regulatory context and read-across
The push for direct Fed account access by non-bank payment firms has been contested for years. Several applications from crypto-adjacent and fintech-focused institutions have stalled or been rejected at the Federal Reserve Bank level, and a series of legal challenges have tested whether the Fed has discretionary authority to deny master account access to federally chartered institutions. The proposed Payment Account framework is partly a response to that litigation and lobbying pressure: rather than leaving access decisions to ad hoc Reserve Bank discretion, the Fed is attempting to establish a codified, risk-tiered pathway.
For the fintech sector, the stakes are significant. Master account access and the associated payment services are currently intermediated almost entirely through traditional bank partners, which introduces both cost and counterparty risk for non-bank payment firms. A dedicated Payment Account category could reduce that dependency, though the eligibility and oversight conditions will determine how many firms can realistically qualify.
The AFC’s emphasis on avoiding duplicative regulation also has a read-across to broader US financial policy. The OCC’s fintech charter effort and state-level money transmission licensing frameworks already create a complex multi-regulator environment. AFC’s recommendation that the Fed co-ordinate implementation across federal agencies reflects a wider industry concern that inconsistent standards across regulators add compliance cost without producing better outcomes.
The Federal Reserve has not announced a timeline for finalising the framework. The AFC letter is a comment submission; the central bank will weigh it alongside responses from banks, consumer groups and other stakeholders before issuing a final rule.
