The Clearing House Association, the Bank Policy Institute, and the Financial Services Forum submitted a joint comment letter on the Federal Reserve's proposal to establish Payment Accounts for certain institutions seeking direct access to Federal Reserve payment services. The proposal represents a significant evolution in Federal Reserve account access policy, with potential implications for the payments system, financial stability, and monetary policy implementation. While supporting responsible innovation, the Associations recommend a transparent, risk-based framework with additional safeguards to ensure consistent account access standards, preserve the safety, resilience, and integrity of the U.S. payments system, and mitigate operational, financial, and illicit finance risks. To read the full letter, click here.