ICBA submitted a response to the Federal Reserve's request for information on a Reserve Bank Payment Account prototype, also known as a skinny master account. ICBA said that while the prototype comes with a number of built-in limits and guardrails, it has significant concerns about expanding direct Federal Reserve account access to institutions that operate outside the traditional banking regulatory framework. ICBA also advocated for a prototype that is a genuine pilot program with stated desired outcomes, explicit account approval criteria, clear limits, strong enforcement mechanisms, mandatory evaluation points, “off-ramp” mechanisms, and transparency requirements.