A License Is Not an Account

Two foreign bank branches licensed this year have asked the Federal Reserve for a master account. Both were placed in Tier 2, and the review runs on its own clock.

On September 18, 2026, the Federal Reserve updated its Master Account and Services Database, the public record of which institutions hold access to Reserve Bank financial services and which are still asking for it. Two entries in the request queue deserve the attention of any foreign bank planning a first US office. Banco Inter, S.A. filed for access for its Miami branch on March 16, 2026. CTBC Bank’s Los Angeles branch filed on July 14, 2026. As of August 31, 2026, both requests were pending, and the Federal Reserve had placed both in Tier 2.

Neither request is unusual. What is instructive is the sequence. The Federal Reserve Board approved Banco Inter’s state-licensed Miami branch on January 16, 2026, and the Federal Reserve Bank of San Francisco approved CTBC Bank’s Los Angeles branch under delegated authority on July 2, 2026. In each case the license came first and the account request followed: two months later for Banco Inter, twelve days later for CTBC. The approval to open an office and the ability to settle directly through a Reserve Bank are separate decisions, made under separate frameworks, on separate timetables.

Three tiers, one open question

The Federal Reserve evaluates account requests under its Guidelines for Evaluating Account and Services Requests, adopted in 2022, which sort requesters into three tiers. Tier 1 review is described as “less intensive and more streamlined” and applies to federally insured institutions. Tier 2 is “intermediate.” Tier 3 is “the strictest level of review.” The guidelines do not say where an uninsured US branch of a foreign bank falls. The database now answers that, at least for these two filings: both were assigned Tier 2 at the outset.

The distinction has a practical consequence for planning. Across the 94 Tier 1 requests the database shows as approved, the median interval from submission to approval was 55 days, by our count. The database records no approved Tier 2 request at all. There is, in other words, no published benchmark for how long a Tier 2 review of a foreign branch takes, and a business plan that assumes the Tier 1 pace is assuming something the record does not show.

What the branch does while it waits

A branch without its own master account is not idle. The database itself recognizes that institutions may access Reserve Bank financial services “by settling transactions in the master account of another depository institution,” and many foreign offices have operated through a correspondent in exactly that way for years. But a branch whose business plan depends on direct Fedwire and FedACH access, on managing intraday liquidity at a Reserve Bank, or on holding reserves there, is a branch whose plan rests on a decision that has not yet been made.

Banco Inter’s Miami branch reported $4 million in assets at June 30, 2026, according to the Federal Reserve’s structure data released on October 6, 2026. That is what an office looks like in its first months, and it is a sensible stage at which to be pursuing direct access rather than depending on it.

Plan the account as its own workstream

For a bank in Latin America or Europe weighing a first US branch or agency, the lesson is one of sequencing rather than difficulty. The account request is effectively a second application, with its own reviewer and its own expectations: the risk profile of the office, its BSA/AML and sanctions program, its operational resilience and settlement arrangements, and the quality of supervision at home. Much of that material is prepared for the license application in any case. Preparing it once, for both audiences, and filing the account request as soon as the license allows, shortens the period in which the new office depends on borrowed access.

The established Florida offices show where that path leads. Banco de Sabadell, Bci, Banco de Crédito del Perú and Banco Davivienda all hold Reserve Bank access for their Miami-area branches, as do the Miami-area agencies of Banco de Bogotá and Banco Pichincha. Itaú Unibanco’s Miami branch has held access since June 2019, and ABANCA’s since November 2018.

A US license puts a foreign bank onshore. Direct access to the Federal Reserve’s payment services is what allows it to operate there on its own terms. The Atlantis team has guided foreign banks through both applications, and we would welcome a conversation about how to sequence them, from the first conversation through the day the office opens for business.