On May 22, 2026, the President issued Executive Order 14405, directing the Federal Reserve to undertake a comprehensive evaluation of the legal and policy framework governing access to Reserve Bank payment accounts and services. The order marks a notable development for financial institutions operating outside the traditional insured depository model, and it signals a federal interest in reexamining how innovation in financial services intersects with the nation's core payment infrastructure.
The evaluation contemplated by the order specifically targets uninsured depository institutions and non-bank financial companies, including firms engaged in digital asset activities. For years, questions surrounding access to Federal Reserve master accounts and payment services have generated significant uncertainty for fintech companies, special-purpose depository institutions, and digital asset firms. By directing the Federal Reserve to study these issues in a structured manner, the executive order opens the possibility that current pathways will be clarified or expanded, with corresponding implications for eligibility criteria, supervisory expectations, and operational requirements.
For clients in the financial services sector, the potential consequences are substantial. Fintech firms that have struggled to obtain direct access to Federal Reserve services may find new opportunities to participate more fully in U.S. payment systems. Digital asset companies, in particular, should consider how a recalibrated framework could affect their ability to settle transactions, hold reserves, and integrate with established financial infrastructure. Non-bank financial companies operating in adjacent areas should also evaluate how revised policies may influence their competitive positioning relative to traditional banking institutions.
At the same time, expanded access may bring heightened regulatory scrutiny. Firms that benefit from new pathways are likely to encounter corresponding obligations relating to risk management, anti-money laundering compliance, operational resilience, and consumer protection. Clients should begin preparing internal assessments of their current frameworks and identifying areas where forthcoming policy changes could require adjustment.
We recommend that affected clients monitor the Federal Reserve's review process closely, including any requests for public comment, interim guidance, or proposed rulemaking that may follow. Early engagement can help shape outcomes and position organizations to respond efficiently once the evaluation concludes.
This update is provided for general informational purposes only and does not constitute legal advice. Clients facing specific questions regarding Executive Order 14405 or related regulatory matters should seek tailored counsel.