TCH submitted comments in response to the Federal Reserve’s request for comment on its proposed amendments to the Guidelines for Evaluating Account and Services Requests. The proposed amendments would require the Federal Reserve banks to periodically publish a list of depository institutions that hold Reserve Bank accounts and or use Reserve Bank financial services. TCH is supportive of the proposed amendments to the Guidelines overall and offered a few comments to further improve them.

• TCH encouraged the Federal Reserve to expand the disclosure to include institutions that have requested, but have not yet been granted, an account or use of services, and further recommended the that Federal Reserve invite public comment on those applications especially with respect to tier three institutions given the risks that such institutions could pose.
• TCH recommended the Federal Reserve disclose both a list of account holders, and non-account holders that use Reserve Bank services.
• TCH recommended that the Federal Reserve revise or clarify the meaning behind the phrase “access to accounts and/or services” by using a separate phrase, such as hold an account or use a service, or otherwise clarifying that an institution that does not have access might still be eligible to hold an account if it applied for one.

To read the full comment letter click here.