Custodia Bank's Master Account Appeal Rejected
Custodia Bank’s attempt to secure a master account with the Federal Reserve has suffered a significant setback. The U.S. Tenth Circuit Court of Appeals ruled in favor of the Federal Reserve, blocking Custodia’s request to gain direct access to the central bank’s payment system. This ruling reinforces the Fed’s authority to limit access to its payment infrastructure, especially when it deems there may be systemic risks involved.
The court’s decision was split, with a 2-1 majority siding with the Fed, affirming that it has the discretion to decide which institutions are eligible for master accounts.
Background of Custodia's Application and Lawsuit
The ruling came after Custodia Bank, a digital-asset-focused institution based in Wyoming, had initially applied for a master account in 2020 through the Kansas City Federal Reserve. Custodia’s request was denied in 2021 due to concerns over the bank’s exposure to digital assets, potential volatility, and challenges regarding regulatory compliance.
Following the denial, Custodia filed a lawsuit, which was dismissed by a Wyoming district court. The latest appellate decision upholds the Fed’s stance, emphasizing that allowing institutions like Custodia access to the payment system without stringent oversight could introduce significant risks.
Concerns Over Crypto Risks and Payment System Integrity
Judges in the majority opinion argued that the Federal Reserve must be able to exercise full control over who gains access to its core payment systems. They warned that granting automatic approvals, especially to businesses with links to volatile industries such as cryptocurrency, could jeopardize the integrity and stability of the U.S. financial infrastructure.
The court acknowledged the importance of safeguarding payment systems from risks associated with crypto-aligned business models.
Dissenting Opinion on Innovation and Oversight
However, there was dissent within the panel. Judge Timothy Tymkovich disagreed with the majority decision, arguing that the Fed could implement layered oversight and monitoring instead of flatly denying access to potentially innovative institutions.
He expressed concern that denying master accounts to banks like Custodia could hinder competition and slow down innovation in the financial sector, particularly in the realm of payments and digital assets.
Implications for Traditional and Digital Asset Firms
The legal battle underscores ongoing tensions between traditional financial institutions and emerging digital-asset firms seeking to access the central banking system. With this ruling, the Federal Reserve’s authority over who is allowed to use its payment system remains firmly intact.

