A National Trust Bank Is a National Bank: Anchorage Digital's Comment Letter to the Federal Reserve

Anchorage Digital Bank National Association (ADB) is proud to share its comment letter responding to the Federal Reserve Board's proposed revisions to the Federal Reserve Policy on Payment System Risk and the Guidelines for Account and Services Requests (Docket No. OP-1878). The proposal would create a new, scaled down "Payment Account" for institutions, like ADB, that don't carry FDIC insurance.

ADB writes from experience, not theory. For over five years, the Bank has operated as America’s first federally chartered national bank supervised by the Office of the Comptroller of the Currency (OCC). ADB is also an applicant: as a member of the Federal Reserve System through the Federal Reserve Bank of Minneapolis, ADB submitted its request for a full Federal Reserve Master Account in August 2025, months before the Board previewed the Payment Account concept. That application remains pending, and under a pause the Board announced alongside this proposal; it may stay undecided through the end of the year. ADB didn't ask for a scaled down account. It asked for the same account that member national banks have held for over a century, and the response so far has been a new service not suited for ADB’s needs and a longer wait.

We welcome the renewed attention to payment system access. Executive Order 14405 requests the Board to reexamine longstanding barriers to account access, and the Board's decision to pause its most stringent account reviews while it develops clearer principles is a constructive step. But getting those principles right starts with a basic fact: a national trust bank is a national bank. The OCC charters and supervises national trust banks under the exact same laws as every other national bank. The only difference is that national trust banks voluntarily limit their business to trust and fiduciary activities, like custody, and don't take insured deposits. That's a choice about deposit protection, not a sign of higher risk. As of March 2026, OCC supervised, uninsured national trust banks held $7.2 trillion in assets under administration, and they're subject to the same enforcement tools regulators use against any insured national bank. Yet the Fed's current guidelines place national trust banks without a Fed regulated holding company in Tier 3, the category reserved for the most stringent review, right alongside institutions that have no federal supervisor at all.

The Payment Account itself doesn't fix that gap. As proposed, it leaves out the services that make a Fed account useful for real payment activity. It excludes FedACH, the network that moved $104.06 trillion, or 74 percent of all noncash payment value, in 2024. It caps how much money an institution can hold in the account overnight, forcing funds to be shuffled elsewhere just to stay under the limit. It offers no intraday credit, which makes routine wire settlement impractical at any real scale. And it pays no interest on the balances institutions do hold there, a mismatch with the GENIUS Act, which expects licensed stablecoin issuers to manage their reserves efficiently. In practice, it's an account you can't fill during the day and have to empty every night, which doesn't solve the underlying dependency on other banks. It's the same dependency, wearing a new name.

Our letter asks the Board to fix this with tools it already has: hold institutions to the business plans their regulators already approved instead of imposing blanket caps, rely on the OCC's existing BSA/AML and sanctions oversight instead of layering on a duplicate review, set clearer and faster timelines for reviewing Master Account applications, and rebuild the tiering framework around actual supervision, not deposit insurance status.

ADB also submitted a companion letter responding to the Federal Reserve's related proposal to amend Regulation D, reinforcing the same point on interest for Payment Account balances. [Read that letter here]

Read Anchorage Digital's Comment Letter to the Federal Reserve Board