
David Portilla
37:15 - 37:52
"The recurring difficulty across chartering, payments licensing, and access to Federal Reserve services is the same. A framework organized around a bundled conception of banking has not fully adapted to a world in which the core banking functions have become increasingly unbundled. The remedy should not be to force new business models into ill-fitting categories."
“The recurring difficulty across chartering, payments licensing, and access to Federal Reserve services is the same. A framework organized around a bundled conception of banking has not fully adapted to a world in which the core banking functions have become increasingly unbundled. The remedy should not be to force new business models into ill-fitting categories.”
Importantly, any legislation about charters or licensing would benefit from corresponding certainty about master account access, because a new charter or license is inherently of relatively limited value if the question of payment system access is left unresolved. To conclude, the recurring difficulty across chartering, payments licensing, and access to Federal Reserve services is the same. A framework organized around a bundled conception of banking has not fully adapted to a world in which the core banking functions have become increasingly unbundled. The remedy should not be to force new business models into ill-fitting categories. Rather, innovation is often best favored by updated and clear legal standards that match today's markets.