The debate over giving fintechs direct access to Federal Reserve payment rails has focused mostly on eligibility. The recent Executive Order 14405 and the Federal Reserve’s payment account proposal make the direction clear: nonbank institutions are being invited closer to the payment rails. The Fed’s proposed payment account is deliberately limited: no discount window, intraday credit, or FedACH, and any transaction that would overdraw the account gets rejected. Banks provide payment access while remaining subject to supervisory oversight and responsible for much of the compliance infrastructure supporting those relationships. Those are aggressive timelines for changes that could reshape how payment access and settlement risk are allocated.