Direct access to the Federal Reserve’s payments system through a master account provides faster settlement, lower operating costs, and greater operational control by eliminating the need for intermediary banks. In 2022, the Fed issued guidelines for how it would evaluate master account applications from a range of entities, including traditional banks, trust companies, and non-FDIC-insured (“uninsured”) “novel” charters. Unfortunately, the Fed’s master account guidelines created structural inequities among similarly situated uninsured institutions. The framework favors federally supervised uninsured entities, such as OCC-licensed national trust banks, over state-supervised uninsured entities. As a result, the Fed’s guidelines may encourage firms to pursue a national trust charter rather than a state charter simply to improve their prospects of securing a master account.