Final Guidelines on Federal Reserve Bank Account Access

Final Guidelines Provide Risk-Based Principles and a Three-Tiered Framework for Evaluating Institutions for Access to Federal Reserve Bank Accounts or Services Sullivan & Cromwell LLP - August 19, 2022

On August 15, 2022, the Board of Governors of the Federal Reserve System (the “Federal Reserve”) adopted final guidelines (“Final Guidelines”) that establish the framework for Federal Reserve Banks to use in evaluating requests to access Federal Reserve Bank master accounts and payment services. These accounts and services are core components of the U.S. payments system. The Final Guidelines are substantially similar to the initial proposed guidelines issued by the Federal Reserve in May 2021 and the supplemental proposal issued in March 2022 (together, the “Proposed Guidelines”), with targeted adjustments in response to public comments regarding the treatment of state-chartered institutions under the three-tiered review framework. For more information on the Proposed Guidelines, please refer to our memoranda to clients from May 6, 2021 and March 10, 2022.