Innovation Within Limits, January 2026 – Federal Reserve Board Proposes “Payment Account” Prototype to Facilitate Payments Innovation While Limiting Reserve Bank Risk

Overview: On December 19, 2025, the Federal Reserve Board issued a Request for Information (“RFI”) on a proposed “Payment Account prototype.” The proposal responds to growing pressure from payments-focused institutions — particularly uninsured and novel charter entities — seeking faster, more predictable access to Federal Reserve payment rails that currently are only available with a Federal Reserve Bank master account….
By: Cadwalader, Wickersham & Taft LLP