Anchorage Digital Bank filed a comment letter with the Federal Reserve on or before the July 27, 2026 deadline, pushing back on the central bank's proposed "payment account" category. The letter, submitted to docket FR-2025-0083-01-C36, argues that the new account type is not a workable substitute for a full master account and identifies three specific gaps the Fed must address before the structure becomes viable for institutions at Anchorage's scale.

A Federal Reserve master account is the foundational mechanism through which any US bank holds reserves at the central bank and connects directly to the country's payment infrastructure, including Fedwire, FedACH, and FedNow. For crypto firms, direct access would eliminate the need for correspondent banks, which have historically been reluctant or, in some cases, restricted from serving digital asset companies, though the source and degree of those restrictions has varied considerably. Without it, institutions like Anchorage must route transactions through intermediaries, adding cost and counterparty risk at every step.

The Fed formally proposed the new payment account category on May 20, 2026, one day after President Trump signed an executive order directing the central bank to review expanding payment access to uninsured depository institutions. The proposal is aimed at entities that are legally eligible for Fed access but not covered by federal deposit insurance, including state-chartered crypto banks and Wyoming Special Purpose Depository Institutions. Fed Governor Chris Waller first outlined the concept publicly in October 2025. The Fed then issued a formal request for information in December 2025, collecting more than 30 comment submissions, before publishing its formal proposal the following May.

Anchorage identified three deficiencies in its comment letter. First, the proposal caps overnight balances at up to $1 billion, a revision upward from an original limit of $500 million or 10 percent of total assets, but Anchorage argues the cap remains operationally constraining for an institution that already holds tens of billions of dollars in digital assets under custody for institutional clients. Second, the payment account excludes access to FedACH, the automated clearing house network used for routine bank-to-bank transactions. Institutions would be limited to Fedwire Funds, FedNow, the National Settlement Service, and Fedwire Securities, meaning everyday ACH-style transfers would still require a correspondent bank intermediary. Third, payment account holders earn no interest on reserves held at Federal Reserve Banks, unlike holders of standard master accounts.

"For the proposed Payment Account to serve as a viable alternative to a full Master Account for eligible institutions, including national trust banks, specific deficiencies regarding overnight balance caps, interest on reserves, and FedACH access must be addressed," Anchorage wrote in its letter. The phrase "including national trust banks" is significant: Anchorage is making an argument on behalf of a class of institutions, not only on behalf of itself.

The firm has a concrete stake in the outcome. Anchorage received its OCC national trust bank charter in January 2021, becoming the first federally chartered crypto bank in the country. A 2022 consent order related to anti-money laundering compliance failures delayed its path to a master account. After the OCC lifted that order in August 2025, CEO Nathan McCauley stated the firm had "proven definitively that crypto and federal oversight are not mutually exclusive." Anchorage filed its formal master account application on August 28, 2025. The Fed has since instructed Reserve Banks to pause all Tier 2 and Tier 3 master account decisions through December 31, 2026, while the payment account rulemaking is finalized, effectively freezing Anchorage's pending application.

Anchorage's current posture reflects an evolution rather than a wholesale rejection of the payment account concept. Rachel Anderika, the firm's Head of Global Operations, described the original skinny master account proposal as "a really great signal to the market" in comments on the American Banker podcast. Anderika subsequently testified before the House Committee on Financial Services on June 24, 2026, addressing Fed payment access and the broader regulatory framework for digital assets. The comment letter that followed represents a judgment that the concept is sound but the specific implementation, as proposed, falls short of operational adequacy for institutions at Anchorage's scale.

Anchorage is not alone in this queue. Ripple, Circle, Paxos, and WisdomTree Digital Trust are among the firms pursuing direct Fed access. The track record for Tier 3 applicants (the category covering novel charter institutions) stands at one approval, three rejections, and roughly 20 pending applications. Kraken Financial received the lone approval in March 2026 from the Kansas City Fed, marking the first time a crypto firm gained direct access to Fed payment rails. Even that account carries restrictions: no interest on reserves and no access to the discount window, conditions that mirror the payment account structure Anchorage is now challenging.

The eligibility paths for firms in this queue are not uniform. Ripple, Circle, and Paxos are stablecoin-adjacent entities whose route to Fed access may be shaped by the GENIUS Act. Legal analysts at Mayer Brown have flagged unresolved ambiguity about whether the GENIUS Act's reserve-holding authorization extends master account eligibility to non-depository stablecoin issuers, a question that could affect several names in the applicant pool differently than it affects Anchorage.

For users outside the United States, the stakes are structural rather than abstract. India is the world's largest remittance recipient and ranks first globally in crypto adoption according to Chainalysis 2025 data. Pakistan ranks third. India's crypto transaction volumes reached roughly $300 billion in the first half of 2025. Stablecoin rails, particularly USDT and USDC, carry an increasing portion of that remittance traffic. Whether Anchorage and similar custodians can settle USD efficiently through Fed infrastructure directly affects the cost and speed of those transfers. In Africa, where sub-Saharan markets account for 70 percent of the global $1 trillion mobile money market, exchanges and payment platforms such as Yellow Card, VALR, and Chipper Cash depend on US-side custodial partners to clear USD for stablecoin operations. Friction in that settlement layer ultimately lands on end users.

The Fed's pause on master account decisions runs through December 31, 2026, making that date the next key milestone for Tier 2 and Tier 3 applicants. Under current guidelines, the Fed is expected to apply a 90-day review timeline to pending applications once the pause lifts. If Anchorage's objections are incorporated into the final rule, or if the firm secures a full master account separately, the institutional custody landscape for digital assets would shift in ways that reach well beyond US borders. The GENIUS Act rulemaking adds a further variable: depending on how regulators resolve the eligibility questions it raises, the pool of institutions qualifying for master account access could expand or shift before the payment account framework is finalized. One dissent is already on record. Fed Governor Michael Barr opposed the proposal, a signal that the final rule could face pressure for stricter anti-money laundering oversight before it is published.