CUNA supports the Federal Reserve Board creating “clear and consistent” guidelines for access to Reserve Bank accounts and services, it wrote Monday. CUNA’s letter is in response to proposed guidelines for evaluating requests for accounts and services at Federal Reserve Banks.

“CUNA supports the Board’s effort to establish clear and consistent guidelines to evaluate requests for master account access to Reserve Bank accounts and services,” the letter reads. “The proposed Guidelines do not address how the Reserve Banks would ensure that new applicants for Reserve Bank accounts and services that are not subject to the rigorous regulations and supervision in place for federally-insured depository institutions or privately-insured state chartered credit unions would demonstrate adequate standards ensuring the safe operation of the payments system.”

CUNA adds that while the current system has worked well, providers other than credit unions and banks will likely seek access, and some could rely on technologies that may pose “unique risks” to the payments system.

The letter also notes:

• The Federal Reserve Board and Reserve Banks should create a uniform evaluation policy and procedures so that the guidelines are deployed consistently across the Reserve Banks when approving an entity to have master account access at a Reserve Bank.
• The guidelines should not impose additional requirements on credit unions or create additional burdens, considering the strict and numerous regulations already in place for their safe and sound operation.
• Working through the robust information already provided by credit unions will ensure the process for application and ensuring ongoing compliance with the guidelines is efficient and seamless.
• The framework creates uniform risk management standards that would help ensure every entity that requests access to Reserve Bank accounts meets minimum standards.
• The Federal Reserve Board should develop a process to monitor entities granted Reserve Bank access on an ongoing basis.
• The Board should develop a floor for capital, liquidity, and risk management requirements for master account access that meets prudential standards in place for federally insured or supervised financial institutions.