Regulatory engagement around digital assets continues to expand as companies seek clearer access to U.S. payment infrastructure. Ripple Labs Inc. submitted a comment letter to the Federal Reserve on Feb. 6, urging modifications to the proposed Reserve Bank Payment Account framework to better accommodate stablecoin issuers and digital payment facilitators.

In its letter, Ripple recommends four key modifications to the Payment Account prototype: granting limited-purpose Discount Window access for permitted payment stablecoin issuers, allowing Interest on Reserve Balances to prevent reserve concentration within commercial banks, replacing the static $500 million overnight cap with a proportional asset-based threshold, and incorporating a pre-funded ACH settlement model to eliminate credit risk.

“The PA prototype offers a critical pathway for Permitted Payment Stablecoin Issuers (PPSIs) to eliminate counterparty risk by holding 1:1 reserves directly at a Federal Reserve Bank, the ‘ gold standard’ for reserve safety and the ultimate realization of the GENIUS Act’s stability objectives,” Ripple’s Chief Legal Officer, Stuart Alderoty, stated. He noted:

“Ripple’s stablecoin, RLUSD, and the cryptocurrency XRP underpinning these solutions allow Ripple and its customers to shape the modern financial system.”

Alderoty further explained: “While XRP – the token native to the XRP ledger – can be utilized as a potent liquidity tool to enable fast and low-cost transfers, the RPD [Ripple Payments Direct] architecture is built to support a diverse range of currencies, tokens, and financial use cases, ensuring transparency and instant settlement regardless of the underlying asset being moved.”

Separately, Ripple has formally applied for federal banking and payment access approvals as it expands beyond its role as a software provider. The company applied for a National Trust Bank Charter through the Office of the Comptroller of the Currency (OCC) on July 2 last year and received conditional approval in December to establish Ripple National Trust Bank. The charter allows Ripple to provide institutional digital asset custody, meet federal stablecoin issuance requirements under the GENIUS Act, and operate nationwide under a single federal framework rather than maintaining individual state licenses.

The crypto firm has also applied for a Federal Reserve Master Account through its subsidiary, Standard Custody & Trust Company, a request that remains under review. A Master Account would provide direct access to Fedwire and FedNow and allow RLUSD reserves to be held at the Federal Reserve. While the Federal Reserve evaluates such applications independently and has historically limited access for crypto-native firms, Ripple’s conditional approval from the OCC positions it among the firms seeking expanded integration with U.S. payment rails.

• What changes did Ripple propose to the Federal Reserve Payment Account framework?
  Ripple proposed Discount Window access, Interest on Reserve Balances, a proportional asset-based cap, and a pre-funded ACH settlement model.
• How would the Payment Account differ from a traditional Master Account?
  The proposed Payment Account would not provide intraday credit, daylight overdrafts, or correspondent banking authority.
• How does RLUSD relate to Ripple’s Federal Reserve proposal?
  Ripple said RLUSD would benefit from holding 1:1 reserves directly at a Federal Reserve Bank under the framework.
• What role does XRP play in Ripple’s payment architecture?
  XRP serves as a liquidity tool enabling fast, low-cost transfers within Ripple’s broader RPD architecture.

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