Part 2 – 3 Scenarios for Fintechs – Fedwire Access

Today, we are diving into Part 2 of my analysis on the implications of the Trump administration’s recent Executive Order. If you missed Part 1, you can catch up here: Fedwire for Fintechs: Opportunities.. Let’s cut to the chase and look at the real-world strategy, the economics, and the top three services that I see as impacted by expanded access.

  • Zelle Killers
  • Digital Wallets
  • High Friction (disfavored) services – The 3 Ps of Payments (Pot, Porn and Poker)
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Fedwire for Fintechs – Opportunities

I want to break down what the May 19, 2026 Executive Order on financial technology actually means for our industry. If you are looking for a basic textbook explanation of Fedwire or the National Settlement Service (NSS), you will not find it here. See my blog Settlement – Core of Banking for how the plumbing works. Today, I’m on what this EO means for Fintechs, with a discussion on the operational constraints likely to occur.

The day after the President signed the executive order, the Federal Reserve Board dropped a formal proposal to establish a special-purpose “Payment Account”. This is a streamlined, payments-only account category designed to bypass the traditional Master Account bottleneck. Under the new framework, the Fed is promising a 90-day review timeline for Tier 2 and Tier 3 non-bank applicants. 

This sounds like a massive win, but as we look at the fine print, the operational reality is a lot more complicated. Here is my breakdown of the core opportunities, the constraints, and the economic hurdles you need to consider.

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Stripe Sessions 2026: Takeaways

It has taken two weeks, but I’m finally 20% through processing Stripe Sessions 2026 (my first). I’ll say it plainly: I was absolutely blown away by the energy, the talent, the ambition, and frankly, the sheer scale of what Stripe is building. My only real complaint? The rooms needed to be bigger. A lot bigger.

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DPCs Great Idea with a Long Way To Go

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Executive Summary

I’m fortunate to chat with a diversity of large payment network stakeholders. As most of you know, I view the challenge in payments more from a political/incentive viewpoint than a technical one. The alphabet soup of new standards is hard to keep up with, but be assured that each one has a proponent (who benefits) and a group of resistors. Innovation in a network is hard, as existing stakeholders have built assets and competitive positions based upon how things work today. Today’s blog covers DPCs. DPCs may not be the biggest threat, but they are the newest. I’m not going to attempt a deep tech dive into DPCs; my effort is focused more on the challenges faced by any new payment innovation to gain traction and scale. Network effects are hard to beat!

Why read this blog? My readers know I view identity and authentication as part of the core “bundle” of payments, and Visa/MA are the de facto identity infrastructure of the internet because they unlock the power of banks (ie KYC) within a commercial framework with active governance. Today we are breaking down the latest “threat”: Digital Payment Credentials (DPCs) within Agentic(ie Gemini, GPay). The quick summary is that DPCs are an amazing technical innovation without a commercial framework or active governance, and thus will be challenged to operate separately from established networks (just like Stablecoins). This 23 page monster blog is a breakdown of the politics and the tech.

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The CLARITY Act Is Locked — And Stablecoin Payments Just Lost Their Best Argument

When I wrote Stablecoin Rewards’s Last Hope – The CLARITY Act in February, the Senate was deadlocked, Coinbase had just walked out of the markup, and the White House was scrambling to hold a fragile coalition together. The central question was whether the Alsobrooks Compromise — activity-based rewards in, idle yield out — could survive the banking lobby long enough to reach a floor vote.

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FIncen/OFAC 303 Page Rule Squashes Stablecoin eCom Ambitions

Exec Summary

  • New 303 Page FINCEN/OFAC Rule, aligns to the clear language of the Genius act, but IMHO will create major friction for use of USD stablecoins in eCommerce
  • Rules for tracking parties and monitoring secondary activity create a compliance regime that burdens every party with the need to understand the provenance of a coin. Can you imagine accepting $2000 for a new TV, shipping it out, then having your stablecoins burned?
  • So not only do we have KYC but we have SAR reporting requirements as PPSIs must also comply with SAR and the “Travel Rule” (31 CFR 1010.410(f)), which involves collecting and transmitting information about the originators and beneficiaries of funds transmittal.
  • Banks and Stablecoin Issuers that jumpted into Solana’s Token-2022 model saw this coming and are well placed to move forward
  • This creates substantial advantages for banks in sweeping coins into covered accounts and freshly minting new coins when required. 
  • Great news for Big Banks and V/MA. card gain signficant advantage over stablecoins with the proposed rule
  • I see this as tailwind for stablecoins in settlement, but a big headwind for stablecoin in eCommerce (with a few exceptions). 
  • My views on Stablecoin winners and losers remain unchanged except for an update to winners for x402.
  • No wonder Jamie Dimon remains confident that the banks will win, it will take years for stablecoin startups to build the regulatory muscle required to manage 303 pages of FinCEN mandates. By the time they do, the banks will already be running their own stablecoin subsidiaries under the very same rules.

The Rule

The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) and OFAC issued a 303-page proposed rule implementing the GENIUS Act, reclassifying permitted payment stablecoin issuers (PPSIs) as financial institutions under the Bank Secrecy Act. Requirements include bank-grade KYC, suspicious activity reporting, transaction blocking/freezing capabilities, and appointment of a U.S.-based compliance officer. Enforcement begins January 2027. A 60-day comment period opens now.

The NPRM (Notice of Proposed Rulemaking) introduces 31 CFR Part 1033, which specifically outlines the obligations of PPSIs. The density of this document reflects the complexity of applying traditional banking rules to a distributed ledger environment.

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Wero 2026: Sovereignty at a Commercial Premium

Just left a UBS webinar from the head of product for Wero and thought it would be a good time to update my July 2025 assessment of Wero as a “solution in search of a problem,”. The biggest change in Wero is the core infrastructure has transitioned from a voluntary service to a mandated utility. However, as the European Payments Initiative (EPI) attempts to scale, the project faces a fundamental conflict between political objectives and commercial unit economics.

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Visa CLI and X402 CONVERGENCE

Last week I wrote about MPP and x402 solving the internet’s original sin: the inability of machines to pay machines without a human in the loop. This week, Visa made that argument a lot easier to make.

Visa Crypto Labs quietly launched Visa CLI, a command line tool that gives AI agents a wallet. One npm install. One setup command. And your agent can pay for anything on the internet, charged to a real Visa card, without an API key, without a pre-funded crypto wallet, without human intervention.

I got beta access this week and tested it. Here’s what I learned, and why I think the CLI is the most important signal yet that the incumbent payment networks are serious about the agentic commerce era.

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The Evolution of Checkout: Invisible, Instant, and Everything In Between

My friend Simon Taylor at Fintech Brainfood published a provocative piece this week: The Checkout is Dead, Part 2. His thesis is elegant — the future of agentic commerce is invisible. No cart. No confirmation screen. No “Pay Now” button. Just an event in the world, and money moves.

IMHO He’s right about the general direction. But he’s wrong about the scope and timeline. Not everything fits in instant, and its really important to look not only at OpenAI’s instant checkout FAILURE at Walmart, but also their internal success (ie Sparky driving 35% sales increase with internal checkout).

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