I keep watching people treat the Fed’s comment period closing as a footnote. It isn’t. It’s the moment the process stopped being theoretical.
Here’s what I think is actually happening. The executive order is signed in May asking the Fed to look at nonbank access to its payment rails. The Fed, right on schedule, puts out a proposal for a “Payment Account” — deliberately narrow, deliberately hedged, the kind of thing a central bank drafts when it’s been told to move but doesn’t want to move fast. Sixty days of comment. Window closes 27 July. Report due to the President 16 September.
Nobody’s asking the obvious question: who actually filed, and what did they say. Because that’s where the real position of the industry sits, not in the executive order and not in the Fed’s careful proposal language. The banks filed to protect their sponsor-bank fee income. The fintechs and crypto firms filed to get direct rail access and cut the banks out of that fee entirely. Somewhere in between is where the Fed lands in September, and the gap between those two positions is bigger than either side is admitting publicly.
I’ll say the contrarian bit plainly: I don’t think this goes anywhere fast, and I think that’s being undersold. A 120-day OCC review under the PACE Act, no Senate companion for that bill, and now a Fed report that’s a recommendation to the President rather than a rule. Every one of these processes produces headlines about “access” and “innovation” and delivers, in practice, another eighteen months of sponsor-bank dependency for anyone who isn’t already large enough to lobby directly. The firms getting excited about this now are mostly the ones who’ll still be paying sponsor-bank fees in 2028.
Where I think this actually bites for a UK operator: not in whether you can get a Fed account, obviously you can’t and don’t need one. It’s in whether your US payments partner is one of the firms betting on fast movement here, because if they’re structuring pricing or roadmap around access that doesn’t materialise on schedule, that risk sits downstream on you.
The PSR’s APP fraud story is the domestic version of the same pattern. Frontier Economics hands the PSR a genuinely good result — fraud down, reimbursement working — and the PSR’s response is a roadmap and a consultation dated for December. Not a fix. A further six months of the two-tier protection gap between Faster Payments and everything else, while the actual structural repair waits on primary legislation that won’t land before the 2026/27 session at the earliest. Good policy outcomes don’t automatically compress timelines. If anything, they seem to buy regulators more room to go slowly, because nobody’s under pressure to move when the headline numbers already look fine.
I’d read both of these the same way: the announcement is not the event. The event is what happens at the deadline nobody’s watching yet — 16 September, December’s consultation. Put those in the diary and ignore the noise in between.
