Karsten Wenzlaff, Advisor
August 26th, 2025
May 26, 2026 | NCFA Insight | Payments And Market Infrastructure, Regulation And Policy, Digital Assets Blockchain And Tokenization

The Fed is proposing limited settlement accounts for eligible firms. The bigger question is whether the U.S. gives qualified fintechs a cleaner infrastructure advantage than Canada.
On May 26, 2026, the Federal Reserve published a Federal Register proposal for special purpose Payment Accounts. Legally eligible institutions could use them to clear and settle certain payment activity through Reserve Bank accounts. Comments are due by July 27, 2026 under Docket No. OP-1878.
The proposal isn't open access to the Fed. Payment Accounts would have no intraday credit, no discount window access, no interest on balances, no correspondent activity, and no respondent activity. Closing balances would generally be capped at $1B. The account would support approved payment settlement, not full banking privileges.
Jerome H. Powell, Fed Chair said:
“The proposed payment account would be tailored to support innovation by serving the clearing and settlement needs of certain eligible institutions while also mitigating material risks to the Reserve Banks and payment system.”
A Master Account gives an eligible institution direct access to Reserve Bank balances and Federal Reserve payment services. The proposed Payment Account is narrower in scope. Firms would not borrow from the Fed, earn interest, receive daylight overdrafts, or use the account as a correspondent banking platform.
The Fed is testing whether limited settlement access can exist without full banking access.
Fintechs, crypto firms, trust companies, and novel chartered institutions have pushed for Fed access because sponsor bank dependence affects cost, timing, liquidity, and settlement certainty. Banks have pushed back because wide access can raise compliance, liquidity, and regulatory arbitrage concerns.
In 2022, the Fed finalized Account Access Guidelines with a tiered review framework. The toughest review applies to institutions that are not federally insured and are not subject to federal prudential supervision at the institution or holding company level.
The 2026 proposal doesn't replace that framework. It creates a tighter account model inside the same access debate.
The proposal discusses use cases raised by commenters, including stablecoin issuer reserve operations, tokenized securities settlement in central bank money, tokenized assets, pay by bank checkout, B2B transfers, instant wages and refunds, and the U.S. dollar leg of cross border transactions.
Those use cases point to the same operating need, clean settlement. Stablecoin issuers need reliable reserve movement. Tokenization platforms need cash settlement closer to central bank money. PSPs need faster payment settlement. Pay by bank providers need lower cost routing. Cross border firms need cleaner dollar leg execution.
Today, many fintechs settle payments through sponsor banks. A fintech sends payment instructions, but the actual settlement usually happens through a commercial bank account connected to central bank rails.
Under the Fed proposal, an approved firm could potentially hold limited settlement balances directly at a Reserve Bank for approved payment activity. That could reduce some dependence on sponsor banks for specific flows.
For a stablecoin issuer, that could improve reserve movement and redemption settlement.
For a pay by bank provider, it could streamline payment routing.
For a tokenization platform, it could support settlement closer to central bank money instead of relying entirely on commercial bank ledger movement.
The proposal would not turn fintechs into banks. Firms would not receive deposit insurance, emergency liquidity, or unrestricted Fed access.
If eligible U.S. firms gain limited Reserve Bank settlement access while Canadian firms remain more dependent on bank intermediaries, U.S. fintechs could gain an operating edge in payment speed, settlement certainty, reserve movement, and cost control.
That edge is important for stablecoins, tokenized securities, pay by bank, B2B payments, cross border transfers, and embedded finance. These markets compete on speed, liquidity use, compliance reliability, and integration cost.
It could also change sponsor bank negotiations. A firm with a credible settlement alternative has more leverage than one with no alternative.
| Question | U.S. Fed Payment Account Proposal | Canada RPAA Registered PSP | Canada Payment Rail Participation |
|---|---|---|---|
| Live today? | No. Proposal only. | Yes | Yes |
| Can hold settlement balances at the central bank? | Only if final rules approve it and the firm qualifies. | No | No by participation alone. |
| Can settle some payments through a central bank account? | Would apply only to approved payment activity. | No | RTR may allow direct settlement for eligible participants that qualify for Bank of Canada settlement accounts. RPAA registration alone doesn't. |
| Still needs sponsor banks? | Yes, but dependence could fall for approved settlement flows. | Yes | Yes, in many cases. |
| Gets full banking powers? | No | No | No |
| Main benefit | Potentially cleaner settlement for stablecoins, tokenized assets, pay by bank, and cross border dollar flows. | Legal operation under Bank of Canada supervision. | Access to payment rails and network participation. |
Canada’s retail payments framework brings PSPs into Bank of Canada supervision. The PSP registry under the RPAA confirms registration status, required fees, and national security screening. Registration does not itself provide limited direct settlement access.
Payments Canada says the Real Time Rail will launch in Q4 2026 as Canada’s instant, data rich exchange and clearing and settlement payment system. RTR is expected to broaden access for eligible participants, including PSPs that meet applicable requirements.
Canada has also legislated a fiat backed stablecoin framework, with detailed rules and implementation still being developed. The framework helps define issuer obligations around reserves, redemption, governance, data security, and Bank of Canada oversight. It does not itself provide payment rail access or limited direct settlement access.
The competitive question is not whether Canada should copy the Fed. It's whether Canada can give qualified PSPs, stablecoin issuers, and tokenization firms a clear access ladder from supervision to rail participation to settlement. If U.S. firms gain a narrow Fed settlement lane while Canadian firms wait for comparable clarity, product speed, treasury efficiency, and sponsor bank leverage may tilt south.
If U.S. firms get limited central bank settlement access, what should Canada let supervised PSPs access once they meet higher standards?
The National Crowdfunding & Fintech Association (NCFA Canada) is a financial innovation ecosystem that provides education, market intelligence, industry stewardship, networking and funding opportunities and services to thousands of community members and works closely with industry, government, partners and affiliates to create a vibrant and innovative fintech and funding industry in Canada. Decentralized and distributed, NCFA is engaged with global stakeholders and helps incubate projects and investment in fintech, alternative finance, crowdfunding, peer-to-peer finance, payments, digital assets and tokens, artificial intelligence, blockchain, cryptocurrency, regtech, and insurtech sectors. Join Canada's Fintech & Funding Community today FREE! Or become a contributing member and get perks. For more information, please visit: www.ncfacanada.org
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