Custodia Bank's Appeal Denied in Master Account Case Against Federal Reserve

In a pivotal legal decision on October 31, 2025, the 10th Circuit Court of Appeals affirmed a lower court ruling that the Federal Reserve is not obligated to grant master accounts to all eligible financial institutions, including Custodia Bank.
Custodia Bank initially filed a lawsuit in 2022 challenging the Federal Reserve's delays and apparent rejection of its master account application. The bank argued that statutory language mandates the Fed to provide such access to qualifying institutions. However, in 2024, a federal court ruled against Custodia, emphasizing the Federal Reserve's discretionary power.
The appeals court’s 2025 ruling upheld this interpretation, reinforcing that the Fed maintains authority to approve or reject master account applications at its discretion. Custodia Bank, while expressing disappointment, highlighted that there was a vigorous dissenting opinion within the court, reflecting ongoing contention around these regulatory decisions.
This case has broader implications, especially amid ongoing discussions about access to Fed payment systems by cryptocurrency firms. Fed Governor Chris Waller has recently proposed the idea of a "skinny master account" for crypto companies, suggesting evolving regulatory frameworks for integrating digital asset firms into traditional banking infrastructures.
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As Custodia Bank considers petitioning for a rehearing, the crypto and financial communities will be watching closely. This ruling highlights the complexities at the intersection of traditional banking institutions, federal regulatory authority, and the rapidly evolving crypto industry.