Fintech Bank Charter
Tracker

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Charter Type Reference Guide

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Fed Master Account — Tier Classification

Under the Fed's August 2022 guidelines, all master account applications are reviewed under a three-tier framework based on the applicant's charter type and federal supervisory status — not firm size or business model. Higher tiers face more intensive review, longer timelines, and greater likelihood of denial. The Fed retains full discretion to deny any application regardless of technical eligibility.

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\n Tier 1\n Streamlined Review\n

Federally Insured & Federally Supervised

Institutions that are both FDIC-insured and subject to supervision by a federal banking agency (OCC, Federal Reserve, or FDIC). This includes nationally chartered banks, state member banks, and federally chartered credit unions. Master account applications receive a streamlined review and are routinely approved, barring unusual circumstances.

Includes: National banks (Varo, Revolut), bank acquisitions (SoFi, LendingClub).

\n FedWire: Direct\n FedACH: Direct\n FedNow: Direct\n Discount Window: Eligible\n

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\n Tier 2\n Enhanced Review\n

Federally Insured but not Supervised — or — Supervised but not Insured

Institutions with either federal insurance or federal supervision, but not both. FDIC-insured ILCs whose parents aren't subject to consolidated Fed supervision, and OCC-supervised trust banks that are not FDIC-insured. Applications receive enhanced scrutiny and the Fed evaluates risks more carefully before approving.

Includes: ILCs (Square, PayPal, Affirm), OCC National Trust Banks (Anchorage, Coinbase, Circle, Ripple, Paxos).

\n FedWire: Possible\n FedACH: Possible\n FedNow: Possible\n Discount Window: Generally No\n

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\n Tier 3\n Strictest Review\n

Neither Federally Insured Nor Federally Supervised

Institutions that are neither FDIC-insured nor supervised by a federal banking agency. Wyoming SPDIs, Georgia MALPBs, and other novel state-chartered entities. The Tenth Circuit (Oct 2025) confirmed the Fed has near-unlimited discretion to deny Tier 3 applicants. Kraken Financial became the first Tier 3 institution approved — on a limited \"skinny account\" basis with a one-year probationary term.

Includes: Wyoming SPDIs (Kraken — approved; Custodia — denied), Georgia MALPBs (Fiserv, Stripe — eligibility unsettled).

\n FedWire: Limited/Possible\n FedACH: Limited/Possible\n FedNow: Not Included\n Discount Window: No\n

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The Fed retains full discretion to deny any application regardless of technical eligibility.

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