Can new “payment accounts” with the federal reserve solve the crypto industry’s banking problem?

Aaron Brogan is the founder and managing partner of Brogan Law, where he advises crypto companies on regulatory strategy, transactions, and policy. He also works with industry groups like the Blockchain Association on comment letters and rulemaking related to crypto banking access and financial regulation.

Timestamps:

➡️ 1:22 — What a Federal Reserve master account is and why crypto firms want one
➡️ 6:34 — “Skinny” payment accounts: what they include—and what they leave out
➡️ 7:16 — The core flaw: no interest, no overdraft protection, and balance constraints
➡️ 10:52 — Why incremental policy wins matter in Washington
➡️ 12:16 — How agency posture—not law—has shifted dramatically since 2024
➡️ 13:09 — Advising clients amid uncertainty: baseline law vs. regulatory signals
➡️ 16:11 — Why now may be the best time to take regulatory risk in crypto
➡️ 16:44 — The biggest risk: a political shift triggered by a “black swan” event
➡️ 18:36 — Onshoring vs. offshore structures: why many crypto projects still leave the U.S.
➡️ 21:53 — Prediction markets, state vs. federal power, and a likely Supreme Court fight

Sponsor: This episode is brought to you by the Decentralization Research Center (DRC), a nonprofit think tank advocating for decentralization in emerging technologies. Learn more at thedrcenter.org.

Resources:

📃 Aaron’s newsletter on so-called “skinny” master accounts, with a discussion of his comment letter on behalf of the Blockchain Association

📖 The Federal Reserve's RFI on Reserve Bank Payment Accounts

✉️ “Brogan Law is Built for War” newsletter by Aaron

Disclaimer: This podcast is for informational and educational purposes only and does not constitute legal or investment advice. Views expressed by the guest are their own and do not necessarily reflect those of their employers. Listening to this podcast does not create an attorney-client relationship.