The Financial Technology Association (FTA) appreciates this opportunity to respond to this request for comment issued by the Board of Governors of the Federal Reserve System (Board) on proposed guidelines (Account Access Guidelines) to evaluate requests for accounts and services at Federal Reserve Banks (Reserve Banks).

The Board’s thoughtful proposed guidelines serve the Board’s interest in addressing risks that all institutions might present to the Federal Reserve payments system and financial stability, and in supporting responsible financial innovation that benefits consumers with greater choice and improved product offerings. The FTA applauds the Board’s current engagement on this important topic and is confident that the result will be the further development of safe, resilient, and robust financial services for American consumers and small businesses.


It is a critical and positive development that in the face of an increasingly concentrated banking landscape in the U.S., select fintech firms are seeking a broad range of statutorily authorized state and federal charters in order to offer consumers and small businesses additional choice, targeted product offerings, and lower costs. Since the mid-1980s, the number of banks in the United States has declined by more than 50% and from 2011 to 2016 only a handful of new FDIC-insured bank charters were approved. Concentration is increasing as well, with the top 15 banks holding over 56% of total deposits in 2020, and only two banks generating nearly half of all ACH payments.

Read the full comment letter here.