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Home Court filings PayServices Bank v. Federal Reserve Bank of San Francisco Memorandum Decision and Order Granting Dismissal — PayServices v. Frbsf (9th Cir.)

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Memorandum Decision and Order Granting Dismissal — PayServices v. Frbsf (9th Cir.)

Filed March 30, 2024 in Payservices v. Frbsf; one of 11 filings from this case.

Record facts

CourtUNITED STATES DISTRICT COURT
Filed2024-03-30

UNITED STATES DISTRICT COURT · No. 1:23-cv-00305-REP · Doc. 42 · 2024-03-30 · Docket on CourtListener

Full text

MEMORANDUM DECISION AND ORDER - 1 
UNITED STATES DISTRICT COURT 
DISTRICT OF IDAHO 
 
 
 
PAYSERVICES BANK, 
Plaintiff, 
vs. 
FEDERAL RESERVE BANK OF SAN 
FRANCISCO, 
Defendant. 
Case No.: 1:23-cv-00305-REP 
MEMORANDUM DECISION AND 
ORDER RE: 
 
DEFENDANT FEDERAL RESERVE 
BANK OF SAN FRANCISCO’S 
MOTION TO DISMISS PLAINTIFF’S 
COMPLAINT FOR DECLARATORY 
AND INJUNCTIVE RELIEF 
(Dkt. 22) 
 
DEFENDANT FEDERAL RESERVE 
BANK OF SAN FRANCISCO’S 
MOTION TO STRIKE THE 
DECLARATION OF LIONEL 
DANENBERG 
(Dkt. 26) 
 
DEFENDANT FEDERAL RESERVE 
BANK OF SAN FRANCISCO’S 
MOTION FOR LEAVE TO FILE A 
NOTICE OF SUPPLEMENTAL 
AUTHORITY 
(Dkt. 34) 
 
 
 
 
This matter comes before the court on Defendant Federal Reserve Bank of San 
Francisco’s (“FRBSF”) Motion to Dismiss Plaintiff’s Complaint for Declaratory and Injunctive 
Relief (Dkt. 22).  FRBSF also files a related Motion to Strike the Declaration of Lionel 
Danenberg (Dkt. 26) and a related Motion for Leave to File a Notice of Supplemental Authority 
(Dkt. 34).  Because Plaintiff PayServices Bank (“PayServices”) has not stated a claim upon 
which relief can be granted, FRBSF’s Motion to Dismiss is granted.  FRBSF’s Motion to Strike 
and Motion for Leave to File a Notice of Supplemental Authority are also granted.  The rulings 
are more particularly explained in the following Memorandum Decision and Order. 
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MEMORANDUM DECISION AND ORDER - 2 
I.  BACKGROUND 
 
This case concerns PayServices’ claim to a “master account” and how FRBSF denied 
PayServices’ application for one.  For context, the Court includes a brief discussion about the 
Federal Reserve System generally, as well as master accounts, before examining PayServices’ 
specific allegations and claims against FRBSF.   
A. 
The Federal Reserve System 
 
The Federal Reserve Act (“FRA”) established the Federal Reserve System in 1913.  12 
U.S.C. § 221 et seq.  Though the Federal Reserve System operates as the central bank of the 
United States, there is no single central bank.  Rather, the Federal Reserve System is a composite 
of several public and private entities: (i) the Federal Reserve Board of Governors (“Board of 
Governors”); (ii) the 12 regional Federal Reserve Banks, including FRBSF; and (iii) the Federal 
Open Market Committee (“FOMC”), the body that sets national monetary policy.  Id at § 222.  
These entities, through the Federal Reserve System, promote the health of the United States 
economy and the stability of its financial system.  See Am. Bankers Ass’n v. United States, 932 
F.3d 1375, 1378 (Fed. Cir. 2019) (“The [FRA] of 1913 established a system to oversee banking 
operations and promote greater economic stability.”) (internal citations omitted); see also The 
Fed Explained: What the Central Bank Does at 1 (11th ed. 2021) (hereinafter “The Fed 
Explained”) (discussing the Federal Reserve System’s five general functions to “promote the 
effective operation of the United States economy and, more generally, the public interest”).1  
 
As the name suggests, the Board of Governors is the central governing body of the 
Federal Reserve System.  McKinley v. Bd. of Governors of the Fed. Rsrv. Sys., 647 F.3d 331, 333 
 
1  Available at https://www.federalreserve.gov/aboutthefed/files/the-fed-explained.pdf.  
The Court takes judicial notice of these materials.  See Lee v. City of Los Angeles, 250 F.3d 668, 
689 (9th Cir. 2001) (“A court may take judicial notice of ‘matters of public record’ without 
converting a motion to dismiss into a motion for summary judgment.”).  
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MEMORANDUM DECISION AND ORDER - 3 
(D.C. Cir. 2011) (the Board of Governors “is the central supervisory authority of the Federal 
Reserve System.”).  Located in Washington, D.C., it is an agency of the federal government that 
reports to and is directly accountable to Congress, and whose seven members (“governors”) are 
nominated by the President of the United States and confirmed by the United States Senate.  12 
U.S.C. §§ 241, 248; see also The Fed Explained at 2.  As the governing body of the Federal 
Reserve System, the Board of Governors oversees the decentralized operations of Federal 
Reserve Banks.  12 U.S.C. § 248(a)(1); see also The Fed Explained at 8. 
But Federal Reserve Banks are themselves “‘private corporations whose stock is owned 
by the member commercial banks within their districts.’”  McKinley, 647 F.3d at 333 (quoting 
Comm. for Monetary Reform v. Bd. of Governors of Fed. Rsrv. Sys., 766 F.2d 538, 540 (D.C. 
Cir. 1985)); see also Lewis v. United States, 680 F.2d 1239, 1241 (9th Cir. 1982) (“Each Federal 
Reserve Bank is a separate corporation owned by commercial banks in the region.”); 12 U.S.C. 
§ 341 (Federal Reserve Banks are “a body corporate”).  Federal Reserve Banks are each 
controlled by their own nine-member board of directors,2 charged with carrying out typical bank 
functions, including “collecting and clearing checks, making advances to private and commercial 
entities, holding reserves for member banks, discounting the notes of member banks, and buying 
and selling securities on the open market.”  Lewis, 680 F.2d at 1241 (citing 12 U.S.C. §§ 341-
361); see also 12 U.S.C. § 301.  As the Federal Reserve System’s “operating arms,” Federal 
Reserve Banks operate as bankers’ banks to much of the banking industry: 
In its role providing key financial services, the Reserve Bank acts, essentially, as a 
financial institution for the banks, thrifts, and credit unions in its District – that is, 
each Reserve Bank acts as a “bank for banks.”  In that capacity, it offers (and 
charges for) services to these depository institutions similar to those that ordinary 
banks provide their individual and business customers: the equivalent of checking 
 
2  The commercial banks that hold stock in their District’s Federal Reserve Bank elect six 
of the directors, while the three remaining directors are appointed by the Board of Governors.  
The Fed Explained at 4; see also 12 U.S.C. §§ 302, 304-305. 
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MEMORANDUM DECISION AND ORDER - 4 
accounts; loans; coin and currency; safekeeping services; and payment services 
(such as the processing of checks and the making of recurring and nonrecurring 
small- and large-dollar payments) that help banks, and ultimately their customers, 
buy and sell goods, services, and securities. 
 
The Fed Explained at 8, 11. 
 
 
Highlighting the coordinated and symbiotic relationship between the Federal Reserve 
System’s distinct parts, Federal Reserve Banks serve as the clearinghouse for information about 
the businesses and needs of local communities in their respective regions.  Id. at 5, 8, 11.  That 
information is then factored into monetary policy decisions by the FOMC3 and other decisions 
made by the Board of Governors.  Id. 
B. 
Master Accounts 
 
A master account is a deposit account that permits a depository institution to make 
deposits into and withdrawals from an account held and administered by its regional Federal 
Reserve Bank.  It is, “put simply, a bank account for banks” that “gives depository institutions 
access to the Federal Reserve System’s services, including its electronic payments system.”  
Fourth Corner Credit Union v. Fed. Rsrv. Bank of Kansas City, 861 F.3d 1052, 1053 (10th Cir. 
2017) (Moritz, J.).  As the Board of Governors more fully explains: 
The master account is both a record of financial transactions that reflects the 
financial rights and obligations of an account holder and the Reserve Bank with 
respect to each other, and the place where opening and closing balances are 
determined.  For each institution, all credits and debits resulting from the use of 
Federal Reserve services at any Federal Reserve office are booked to this single 
master account at one Reserve Bank.    
 
Id. at 1064, n.1 (Bacharach, J.) (citation omitted).  “Without such access, a depository institution 
is nothing more than a vault.”  Id. at 1053 (Moritz, J.) (internal quotation marks omitted).   
 
3  The FOMC consists of 12 voting members: (i) the seven members of the Board of 
Governors; (ii) the president of the Federal Reserve Bank of New York; and (iii) four of the 
remaining 11 Reserve Bank presidents, who serve one-year terms on a rotating basis.  The Fed 
Explained at 8, 12.  
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MEMORANDUM DECISION AND ORDER - 5 
In 1980, Congress passed the Depository Institutions Deregulation and Monetary Control 
Act of 1980 (“MCA”).  Pub. L. No. 96-221.  Up until that time, deposit accounts with Federal 
Reserve Banks were limited to the United States Government and Federal Reserve “member” 
banks.  The MCA changed that.  It amended the FRA to allow nonmember depository 
institutions access to Federal Reserve Bank services.  See 12 U.S.C. § 342 (adding “other 
depository institutions” to the list of entities from which Federal Reserve Banks “may receive” 
deposits); see also Compl. at ¶ 65 (Dkt. 1).  The MCA also gave depository institutions equal 
access to the same pricing for Federal Reserve Bank services.  See 12 U.S.C. § 248a(c)(2); see 
also Compl. at ¶¶ 66, 69 (Dkt. 1) (citing 12 U.S.C. § 248(a)(c)(2)).    
 
Then, on August 19, 2022, in response to the rapidly-evolving payments landscape and 
uptick in novel charter types, the Board of Governors adopted “Guidelines for Evaluating 
Account and Services Requests” (“Guidelines”) to provide guidance to Federal Reserve Banks.  
87 Fed. Reg. 51,099 (Aug. 19, 2022); see also Compl. at ¶ 78 (Dkt. 1).  Section 1 of the 
Guidelines adopted six principles4 that Federal Reserve Banks are to use when evaluating 
requests for master accounts and access to Federal Reserve Bank services.  87 Fed. Reg. at 
51,106.  Section 2 of the Guidelines set forth a tiered review framework to “serve as a guide to 
 
4  The Guidelines are predicated on the following six principles: (i) “Each institution 
requesting an account or services must be eligible under the Federal Reserve Act or other federal 
statute to maintain an account at a Reserve Bank and receive Federal Reserve services and 
should have a well-founded, clear, transparent, and enforceable legal basis for its operations”; (ii) 
“[p]rovision of an account and services to an institution should not present or create undue credit, 
operational, settlement, cyber, or other risks to the Reserve Bank”; (iii) “[p]rovision of an 
account and services to an institution should not present or create undue credit, liquidity, 
operational, settlement, cyber, or other risks to the overall payment system”; (iv) “[p]rovision of 
an account and services to an institution should not create undue risk to the stability of the U.S. 
financial system”; (v) “[p]rovision of an account and services to an institution should not create 
undue risk to the overall economy by facilitating activities such as money laundering, terrorism 
financing, fraud, cybercrimes, or other illicit activity”; and (vi) “[p]rovision of an account and 
services to an institution should not adversely affect the Federal Reserve’s ability to implement 
monetary policy.”  87 Fed. Reg. at 51,099.  
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MEMORANDUM DECISION AND ORDER - 6 
the level of due diligence and scrutiny” that Federal Reserve Banks are to apply to requests from 
different types of institutions.  Id. at § 51,109.  The three tiers are: (i) “Tier 1: Eligible 
institutions that are federally insured”; (ii) “Tier 2: Eligible institutions that are not federally 
insured but are subject (by statute) to prudential supervision by a federal banking agency”; and 
(iii) “Tier 3: Eligible institutions that are not federally insured and are not considered in Tier 2.”  
Id. at 51,109-10.  “Although institutions in a higher tier will on average face greater due 
diligence and scrutiny than institutions in a lower tier,” Federal Reserve Banks maintain the 
“authority to grant or deny an access request by an institution in any of the three proposed tiers    
. . . on a case-by case, risk-focused bases.”  Id. at 51,109; see also id. at 51,110 (after discussing 
characteristics of Tier 3 institutions: “Accordingly, Tier 3 institutions will generally receive the 
strictest level of review”).  Ultimately, the Guidelines are “designed to provide additional 
transparency into the expected review process based on key characteristics.”  Id. at § 51,109; see 
also id. at § 51,106 (“These Account Access Guidelines also serve to inform requestors of the 
factors that a Reserve Bank will review in any access request and thereby allow a requestor to 
make any enhancements to its risk management, documentation, or other practices to attempt to 
demonstrate how it meets each of the principles.”).   
C. 
PayServices, Its Request for a Master Account, and This Action 
 
PayServices is a private Idaho depository institution that “focuses almost exclusively on 
facilitating trade commodities for the small to medium enterprises from and to the United 
States.”  Compl. at ¶¶ 2-4, 44, 46(i) (Dkt. 1).  It is not a lender, but instead provides payment 
processing to foreign merchants, buyers, and governments “by linking the actual transaction to a 
physical verification of the merchandise by the customs agencies of both the United States and 
the equivalent agency of the receiving country.”  Id. at ¶¶ 46(i)-(ii), 47.  “PayServices will only 
release the funds allocated for the transaction once it has received confirmation from the 
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MEMORANDUM DECISION AND ORDER - 7 
authorities that the transaction complies with applicable law and presents no danger to the 
public.”  Id. at ¶ 48.  According to PayServices, its model “focuses almost exclusively on one 
area, but does it extremely well.”  Id. 
 
Given its business model, PayServices needs a master account.  So, on August 10, 2022, 
one week after it secured preliminary approval from the Idaho Department of Finance to 
establish a state-chartered bank in Idaho, PayServices applied to FRBSF to obtain one.  Id. at 
¶¶ 3, 23.  PayServices contends that, without a master account, it “cannot directly access the 
Federal Reserve and cannot provide transaction-related services for a variety of customers, 
including importers and exporters, that other banks with master accounts at the Federal Reserve 
presently provide.”  Id. at ¶¶ 1, 70, 72.  Likewise, without a master account, PayServices claims 
that it would be “relegated to depending on an intermediary bank, which prevents it from 
managing the settlement of transactions and services related to foreign trade that it has uniquely 
positioned itself to handle.”  Id. at ¶¶ 1, 98.  In short, PayServices’ success depends on having a 
master account.   
 
On May 31, 2023, FRBSF denied PayServices’ request for a master account.  Id. at ¶ 43  
FRBSF’s two-page denial letter reasoned: 
FRBSF is unable to grant your request because the request does not meet the 
standards outlined in the Board of Governors’ Guidelines for Evaluating Account 
and Service Requests (Guidelines).  PayServices has obtained “preliminary 
approval” from the Idaho Department of Finance to establish an uninsured Idaho 
state-chartered bank and would not be subject to prudential supervision by a federal 
banking agency.  PayServices intends to operate exclusively as an online bank and 
to focus its business model almost entirely on providing payment processing 
solutions to foreign import and export merchants and buyers, and foreign 
governments.  Under the Guidelines, PayServices is a Tier 3 institution and thus 
subject to the strictest level of review.  The proposed, novel, monoline business 
model and focus on transactions that are largely foreign in nature or involve mostly 
foreign participants presents undue risk. 
 
PayServices Bank’s unproven risk management framework is considered 
insufficient to address the heightened risks associated with its novel, monoline 
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MEMORANDUM DECISION AND ORDER - 8 
business model, including its ability to mitigate money laundering and terrorism 
financing risks.  Most notably, the significant risks and concerns in the areas of 
[Bank Secrecy Act]/[Anti-Money Laundering] and [Office of Foreign Assets 
Control] risk management, credit and settlement process and controls, cyber and 
information security risk management, enterprise risk management, strategic 
planning, and the limited banking and bank-specific risk management experience 
among management, presents undue risk to the Reserve Bank.  The proposal also 
presents potential concerns with respect to PayServices’ ability to be resolved 
safely and effectively upon failure, due to its uninsured status.  Should the 
institution allow the Master Account to fund or facilitate illicit activity, undue 
reputational risk may also be posed to the Reserve Bank, Payment and/or U.S. 
financial system. 
 
Ex. A to Karp Decl. (Dkt. 22-2).   
 
PayServices disagrees with the justification given for FRBSF’s denial of its master 
account request, and separately posits that it runs contrary to the dual chartering system and 
state-level banking regulation.   See generally Compl. at ¶¶ 46-64 (Dkt. 1).  This action, 
however, is much more fundamental than that.  PayServices asserts that, because it was eligible 
to receive a master account in the first instance – as a state-chartered depository institution –  
FRBSF was required as a matter of law to issue it a master account.  Id. at 16 (“Federal law 
requires the issuance of master accounts to eligible depository institutions.”); see also id. at ¶¶ 1, 
69, 81, 89, 92, 95, 101-103.  PayServices in turn brings three interrelated claims against FRBSF 
under (i) the Administrative Procedures Act (“APA”); (ii) the Mandamus Act; and (iii) the Due 
Process Clause of the Fifth Amendment.  Id. at ¶¶ 73-103.  These claims seek the same relief: a 
court order requiring FRBSF to grant PayServices a master account.  
 
FRBSF now moves to dismiss PayServices’ Complaint, arguing that (i) each claim must 
be dismissed because FRBSF had discretion to deny PayServices’ request for a master account; 
(ii) each claim must alternatively be dismissed because FRBSF is not an agency of the federal 
government; (iii) the APA claim itself must alternatively be dismissed because FRBSF’s 
decision to deny PayServices a master account was not arbitrary or capricious; and (iv) the Due 
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MEMORANDUM DECISION AND ORDER - 9 
Process claim itself must alternatively be dismissed because PayServices has not alleged that it 
was denied procedural protections.  See generally Mem. ISO MTD (Dkt. 22-1).  On January 25, 
2024, the Court heard oral argument on FRBSF’s Motion to Dismiss.  For the reasons discussed 
below, the Court grants that Motion.5        
II.  LEGAL STANDARD 
 
Federal Rule of Civil Procedure 12(b)(6) allows a court to dismiss a complaint for 
“failure to state a claim upon which relief can be granted.”  Fed. R. Civ. P. 12(b)(6).  When 
evaluating a Rule 12(b)(6) motion, the court accepts as true all well-pleaded factual allegations 
in the complaint, while disregarding unsupported legal conclusions.  Ashcroft v. Iqbal, 556 U.S. 
662, 678 (2009).  Next, having identified the adequately-pleaded facts, the court “determine[s] 
whether they plausibly give rise to an entitlement to relief.”  Id. at 679.  Stated concisely, “[t]o 
survive a motion to dismiss, a complaint must contain sufficient factual matter, accepted as true, 
to state a claim to relief that is plausible on its face.”  Id. at 678. 
III.  DISCUSSION 
A. 
Each of PayServices’ Claims Must Be Dismissed Because FRBSF Had Discretion to  
Deny PayServices Request for a Master Account 
 
 
The FRA does not provide a private right of action.  Still, PayServices pursues one 
against FRBSF via the APA (5 U.S.C. § 706(2)), the Mandamus Act (28 U.S.C. § 1361), and the 
Due Process Clause of the Fifth Amendment.  The success of each of these claims depends on 
the existence of a nondiscretionary duty to make a master account available to PayServices 
through which it can access Federal Reserve Bank services.  See 5 U.S.C. § 701(a)(2) (the APA 
 
5  Alongside its underlying Motion to Dismiss, FRBSF also (i) moves to strike the 
Declaration of Lionel Danenberg (submitted in support of PayServices’ opposition to FRBSF’s 
Motion to Dismiss) (Dkt. 26); and (ii) moves for leave to file a notice of supplemental authority 
(Dkt. 34).  Though not emphasized herein, these motions are resolved within the broader context 
of FRBSF’s Motion to Dismiss – which the Court primarily focuses upon.    
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MEMORANDUM DECISION AND ORDER - 10 
does not apply when “agency action is committed to agency discretion by law”); Pittston Coal 
Grp. v. Sebben, 488 U.S. 105, 121 (1988) (“The extraordinary remedy of mandamus under 28 
U.S.C. § 1361 will issue only to compel the performance of a clear nondiscretionary duty”); 
M.H. v. Jeppesen, 2023 WL 4080542, at *17 (D. Idaho Jun. 20, 2023) (“If government officials 
have the discretion to grant or deny a benefit, that benefit is not a protected property interest” to 
support a Due Process claim) (citing Ching v. Mayorkas, 725 F.3d 1149, 1155 (9th Cir. 2013)).  
PayServices alleges that there is the requisite nondiscretionary duty here because 12 U.S.C. 
§ 248a(c)(2) requires that it be issued a master account.  Compl. at ¶¶ 81, 95, 103 (Dkt. 1) (citing 
§ 248a(c)(2) in support of all three of its claims).  PayServices’ entire case therefore rises and 
falls with whether § 248a(c)(2) requires that FRBSF issue it a master account.   
 
FRBSF responds that it does not.  Indeed, it argues that § 248a(c)(2) is “irrelevant” 
because it neither entitles PayServices to a master account nor imposes any duties on Federal 
Reserve Banks relating to master accounts.  Mem. ISO MTD at 9 (Dkt. 22-1).  According to 
FRBSF, § 248a(c)(2) only instructs the Board of Governors – not Federal Reserve Banks – to 
guarantee that the Federal Reserve System does not price discriminate between member and 
nonmember banks.  Id.  Instead, FRBSF argues that 12 U.S.C. § 342 provides Federal Reserve 
Banks with discretion to grant or deny master accounts.  Id. at 8-9.  Given this discretion, says 
FRBSF, PayServices’ claims against it cannot stand.  Id. at 6-15. 
 
These dueling positions frame a lynchpin issue before the Court: must Federal Reserve 
Banks grant master accounts to an otherwise eligible depository institution regardless of its risk 
profile?  The Court agrees with FRBSF that they do not. 
1. 
12 U.S.C. § 342 
 
The Court’s analysis begins with § 342 – a section that, since its enaction in 1913, 
appears in Subchapter IX of Chapter 3 of Title 12 of the United States Code.  Subchapter IX is 
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MEMORANDUM DECISION AND ORDER - 11 
notably titled: “Powers and Duties of Federal Reserve Banks.” (Emphasis added).  Consistent 
with this direction to Federal Reserve Banks, § 342 specifically states that a Federal Reserve 
Bank “may receive from any of its member banks, or other depository institutions, . . . deposits 
of current funds in lawful money, national-bank notes, Federal reserve notes, [etc.]”  12 U.S.C. 
§ 342 (emphasis added).  The United States Supreme Court has confirmed that this language 
does not “impose[ ] upon reserve banks any obligation to receive” deposits, but “merely confers 
authority to do so.”  Farmers & Merchs. Bank v. Fed. Rsrv. Bank of Richmond, 262 U.S. 649, 
662 (1923) (rejecting an argument similar to PayServices’ that “the Federal Reserve Bank of 
Richmond is obliged to receive for collection any check upon any North Carolina state bank”); 
see also Biden v. Texas, 597 U.S. 785, 803 (2022) (“The statute says ‘may.’  And ‘may’ does not 
just suggest discretion, it clearly connotes it.”) (internal quotation marks omitted) (emphasis in 
original).  The Supreme Court further observed that the discretionary and nondiscretionary 
aspects of the FRA were no accident, stating: “[t]his statute appears to have been drawn with 
great care.  Throughout the act the distinction is clearly made between what the board and the 
Reserve Banks ‘shall’ do and what they ‘may’ do.”  Farmers & Merchs., 262 U.S. at 663. 
 
The Federal Reserve Banks’ discretionary deposit-taking function continued through the 
enactment of the MCA in 1980.  At that time, Congress amended § 342 to authorize Federal 
Reserve Banks to open deposit accounts to both member banks and nonmember depository 
institutions.  Supra.  Importantly, however, the MCA did not disturb § 342’s “may receive” 
language that Farmers & Merchants construed as giving Federal Reserve Banks the discretion to 
receive deposits.  Congress can therefore be presumed to have “accepted and ratified” this same 
position within the MCA.  See Texas Dep’t of Hous. & Cmty. Affairs v. Inclusive Communities 
Project, 576 U.S. 519, 536 (2015) (Congress’ decision to amend the Fair Housing Act while still 
adhering to the operative language within particular sections “is convincing support for the 
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MEMORANDUM DECISION AND ORDER - 12 
conclusion that Congress accepted and ratified the unanimous holdings of the Courts of Appeals 
finding disparate-impact liability.”); see also Forest Grove School Dist. v. T.A., 557 U.S. 230, 
243, n.11 (2009) (“When Congress amended IDEA without altering § 1415(i)(2)(C)(iii), it 
implicitly adopted [the Supreme Court’s] construction of [that same] statute.”).  Thus, § 342 
gives Federal Reserve Banks the discretion to receive or reject deposits from an institution.  
 
Given the role of master accounts within the Federal Reserve System, this discretion 
necessarily means that Federal Reserve Banks similarly have the discretion to grant or deny 
account access.  See Banco San Juan Internacional, Inc. v. Fed. Rsrv. Bank of New York, 2023 
WL 7111182, at *7 (S.D.N.Y. Oct. 27, 2023) (“BSJI’s statutory claim fails because 12 U.S.C. 
§ 342 makes clear that Federal reserve banks are authorized to maintain Master Accounts, but 
are not required to do so.”) (emphasis added);6 see also Custodia Bank, Inc. v. Fed. Rsrv. Board 
of Governors, 640 F. Supp. 3d 1169, 1183 (D. Wyo. Nov. 11, 2022) (noting that the argument 
that “the discretion to receive or reject deposits necessarily carries with [it] the discretion to grant 
or deny master accounts[,] . . . presents as logical[.]”).7  This parallel discretion is not just 
commonsensical; it aligns with the Federal Reserve System’s charge to provide a safe, flexible, 
 
6  FRBSF asks that the Court consider this supplemental authority (entered after the 
completion of briefing on FRBSF’s Motion to Dismiss) on the issue of PayServices’ ability to 
bring the same claims asserted here, and under similar circumstances (albeit presented in the 
context of a motion for preliminary injunction, not a motion to dismiss).  Mot. for Leave to File 
Not. of Supp. Authority (Dkt. 34).  The Court grants the Motion and recognizes this recent 
authority as adding to the evolving state of the law on the issues presented within FRBSF’s 
Motion to Dismiss, particularly given the absence of Ninth Circuit case law in this same area.     
  
7  In Custodia Bank, U.S. District Judge Scott Skavdahl denied a similar motion to 
dismiss made by a defendant Federal Reserve Bank.  Custodia Bank, 640 F. Supp. 3d at 1185.  
He cited (i) an opinion out of the Tenth Circuit (which includes the District of Wyoming), 
Fourth Corner Credit Union v. Fed. Rsrv. Bank of Kansas City, 861 F.3d 1052 (10th Cir. 2017); 
and (ii) the need to more fully develop the record in light of the plaintiff’s allegations against the 
Board of Governors.  Id.  But Custodia Bank does not compel a similar result here because, for 
the reasons stated herein, Fourth Corner does not apply and is distinguishable (infra), and there 
is not a similar need to develop the record based upon PayServices’ allegations.     
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MEMORANDUM DECISION AND ORDER - 13 
and stable financial system.  Supra.  To be sure, the Federal Reserve System expressly permits as 
much.   
For example, the August 2022 Board of Governors’ Guidelines repeatedly underscore 
that Federal Reserve Banks have the absolute discretion to grant or deny master account 
requests: 
The Board intended for the Original Proposal to support consistency in evaluating 
account access requests across Reserve Banks, while maintaining the discretion 
granted to the Reserve banks under the Federal Reserve Act to grant or deny 
access requests. 
 
. . . . 
 
Reserve Banks also retain the discretion to deny a request for access to accounts 
and services where, in the Reserve Bank’s assessment, granting access to the 
institution would pose risks that cannot be sufficiently mitigated.  
 
. . . . 
 
The Board also added language in the final Account Access Guidelines that 
clarifies the respective roles of the Board (Reserve Board oversight) and the 
Reserve Banks (discretion in decision making) with respect to evaluating access 
requests. 
 
. . . . 
 
The Board believes it is important to make clear that legal eligibility does not 
bestow a right to obtain an account and services.  While decisions regarding 
individual access requests remain at the discretion of the individual Reserve 
Banks, the Board believes it is important that the Reserve Banks apply a consistent 
set of guidelines when reviewing such access requests to promote consistency 
across Reserve Banks and to facilitate equitable treatment across institutions.  
 
. . . . 
 
These guidelines broadly outline considerations for evaluating access requests but 
are not intended to provide assurance that any specific institution will be granted 
an account and services.  The individual Reserve Bank will evaluate each access 
request on a case-by-case basis.  When applying these account access guidelines, 
the Reserve Bank should factor, to the extent possible, the assessments of an 
institution by state and/or federal supervisors into its independent analysis of the 
institution’s risk profile.  The evaluation of an institution’s access request should 
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MEMORANDUM DECISION AND ORDER - 14 
also consider whether the request has the potential to set a precedent that could 
affect the Federal Reserve’s ability to achieve its policy goals now or in the future. 
 
87 Fed. Reg. at 51,100, 102-103, 106 (emphasis added).8     
Moreover, in December 2022, Congress amended the FRA to require the Board of 
Governors to “create and maintain a public, online, and searchable database that contains . . . a 
list of every entity that submits an access request for a reserve bank master account and services  
. . . including whether, and the dates on which a request was submitted; and was approved, 
rejected, pending, or withdrawn.”  12 U.S.C. § 248c(b)(1)(B) (emphasis added).  Though the 
reasons for rejecting a master account request may vary, this section acknowledges that master 
accounts do not automatically follow a request for one, as PayServices suggests is the case.  See 
Banco San Juan, 2023 WL 7111182, at *7 (holding that § 248c(b)(1)(B) “confirms that Federal 
reserve banks may ‘reject’ [master account] applications from depository institutions”). 
Finally, “Operating Circulars” exist to establish the terms by which a depository 
institution may request to open, maintain, and terminate a master account with the Federal 
Reserve Bank in its district.  See, e.g., Federal Reserve Banks Operating Circular No. 1 (Account 
Relationships) at ¶ 1.0 (Sept. 1, 2023) (hereinafter “OC-1”).9  Particularly relevant here, OC-1 
states that a Federal Reserve Bank “has discretion in deciding whether to provide a Financial 
Institution with access to a Master Account and may require a Financial Institution to provide 
additional information and documentation to the Reserve Bank to support its decision making.”  
Id. at ¶ 2.6.   
 
8  Deference to the Board’s interpretation of the FRA – the statute it is tasked with 
administering – is appropriate.  See Int’l Bd. of Teamsters, Local 2785 v. Fed. Motor Carrier 
Safety Admin., 986 F.3d 841, 849 (9th Cir. 2021).  
 
9  Available at http://www.frbservices.org/binaries/content/assets/crsocms/resources/ 
rules-regulations/090123-operating-circular-1.pdf.  The Court takes judicial notice of these 
materials.  See supra (citing Lee, 250 F.3d at 689).   
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MEMORANDUM DECISION AND ORDER - 15 
Taken together, by virtue of these pronouncements, the Board of Governors, Congress, 
and Federal Reserve Banks variously contemplate that the FRA affords Federal Reserve Banks 
the discretion to grant or deny master accounts to depository institutions.  PayServices cites 
precious little congressional or agency interpretation of § 342 to the contrary. 
2. 
12 U.S.C. §  248a(c)(2) 
 
In response, PayServices counters that § 342 does not address master account access, but 
rather presupposes that a depository institution already has a master account, and that Federal 
Reserve Banks only have discretion with respect to the types of monetary instruments that it may 
receive for deposit or collection (from master account holders).  Opp. to MTD at 7 (Dkt. 23).  
PayServices then argues that another section from the MCA – § 248a(c)(2) – actually applies to 
compel Federal Reserve Banks to issue master accounts when eligible depository institutions 
request one.  Id. at 7-8 (citing Fourth Corner, 861 F.3d at 1074 (Bacharach, J.) (“Section 342 
addresses the types of monetary instruments that Federal Reserve Banks may receive for deposit 
or collection . . . .  But Section 342 does not address which institutions can access Federal 
Reserve services; that subject is governed instead by Section 248a(c)(2), which enables open 
access to Federal Reserve services for all nonmember depository institutions.  As a result, 
Section 342 does not affect Fourth Corner’s entitlement to a master account.”)).  The Court 
disagrees that either § 248a(c)(2) or Fourth Corner applies to require that FRBSF issue 
PayServices a master account. 
 
In pertinent part, § 248a provides: 
Pricing of services 
 
(a) 
Publication of pricing principles and proposed schedule of fees; 
effective date of schedule of fees 
 
[T]he Board shall publish for public comment a set of pricing principles in 
accordance with this section and a proposed schedule of fees based upon 
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MEMORANDUM DECISION AND ORDER - 16 
those principles for Federal Reserve bank services to depository institutions, 
and . . . the Board shall begin to put into effect a schedule of fees for such 
services which is based on those principles. 
 
. . . . 
 
(c) 
Criteria applicable 
 
 
The schedule of fees prescribed pursuant to this section shall be based on  
the following principles: 
 
(1) 
All Federal Reserve bank services covered by the fee schedule shall  
be priced explicitly. 
 
 
 
(2) 
All Federal Reserve bank services covered by the fee schedule shall  
be available to nonmember depository institutions and such services  
shall be priced at the same fee schedule applicable to member banks,  
except that nonmembers shall be subject to any other terms, 
including a requirement of balances sufficient for clearing purposes,  
that the board may determine are applicable to member banks. 
 
 
 
(3) 
Over the long run, fees shall be established on the basis of all direct  
and indirect costs actually incurred . . . . 
 
 
 
(4)  
Interest on items credited prior to collection shall be charged at the  
current rate applicable in the market for Federal funds. 
 
12 U.S.C. § 248a (emphasis in original). 
 
 
Most obviously problematic to PayServices’ claim is that § 248a(c)(2) appears in 
Subchapter II of Chapter 3 of Title 12 of the United States Code.  Subchapter II is notably 
entitled:  “Board of Governors of the Federal Reserve System.”  So, unlike § 342, which 
specifically applies to Federal Reserve Banks (supra), § 248a(c)(2) applies only to the Board of 
Governors.  See INS v. Nat’l Ctr. for Immigrants’ Rights, Inc., 502 U.S. 183, 189 (1991) (“[T]he 
title of a statute or section can aid in resolving an ambiguity in the legislation’s text.”).  Except 
the Board of Governors does not issue master accounts, Federal Reserve Banks do.  Supra; see 
also, e.g., Compl. at ¶¶ 23, 36 (PayServices alleging that it applied to FRBSF for a master 
account and that FRBSF denied its application for a master account).  On this point, the Court 
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MEMORANDUM DECISION AND ORDER - 17 
agrees with FRBSF that “[i]t would be anomalous for Congress to hide a requirement that 
Reserve Banks must grant direct master accounts to all depository institutions, irrespective of 
risk presented, in a provision that is not even addressed to the Reserve Banks.”  Mem. ISO MTD 
at 10 (Dkt. 22-1) (citing Whitman v. Am. Trucking Ass’ns, 531 U.S. 457, 468 (2001) (“Congress, 
we have held, does not alter the fundamental details of a regulatory scheme in vague terms or 
ancillary provisions – it does not, one might say, hide elephants in mouseholes.”) (emphasis 
added)); see also Banco San Juan, 2023 WL 7111182, at *8 (“If Congress intended to require 
Federal reserve banks to provide specific services, the direction would reasonably have been 
found in the section dealing with the duties and powers of Federal reserve banks and not in the 
section dealing with fee schedules set by the Board.”). 
 
Section 248a’s language does nothing to resolve this tension in a way that supports 
PayServices’ argument.  Just the opposite, with § 248a’s title indicating upfront that it speaks to 
the “[p]ricing of services,” before unsurprisingly describing how the Board of Governors is 
tasked with “publish[ing] . . . pricing principles . . . and a proposed schedule of fees based upon 
those principles for Federal Reserve bank services to depository institutions.”  12 U.S.C. 
§ 248a(a).  As to the referenced “schedule of fees,” § 248a(c) then directs that (i) “[a]ll Federal 
Reserve bank services covered by the fee schedule shall be priced explicitly,” and (ii) “[a]ll 
Federal Reserve bank services covered by the fee schedule shall be available to nonmember 
depository institutions and such services shall be priced at the same fee schedule applicable to 
member banks[.]”  Id. at §§ 248a(c)(1),(2).  Despite this straightforward guidance on pricing, 
PayServices maintains that § 248a(c)(2) requires the issuance of a master account because the 
only way Federal Reserve Bank services are available to nonmember depository institutions in 
the first place is through a master account.  Opp. to MTD at 8 (Dkt. 23) (citing Fourth Corner, 
861 F.3d at 1071 (Bacharach, J.)).  
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MEMORANDUM DECISION AND ORDER - 18 
 
There is admittedly a syllogism to PayServices’ position when considering § 248a(c)(2) 
in isolation.  But read in context, § 248a(c)(2) does not operate to mandate access to the services 
covered by any “fee schedule” via a master account.  It is more appropriately understood to be an 
anti-price discrimination provision benefitting nonmember depository institutions: it confirms 
that a nonmember bank with access to the Federal Reserve System will pay the same for those 
services as a member bank.  See Banco San Juan, 2023 WL 7111182, at *7 (rejecting argument 
that § 248a(c)(2) speaks to, let alone requires, master accounts, stating that it “is best read as a 
clause preventing price discrimination in favor of banks that are members of the Federal Reserve 
System” and “the section does not even state that the services covered by the fee schedule shall 
be available to ‘all nonmember depository institutions’”); see also Jet Courier Servs., Inc. v. Fed. 
Rsrv. Bank of Atlanta, 713 F.2d 1221, 1227 (6th Cir. 1983) (explaining that the services offered 
by Federal Reserve Banks under § 248a “are to be made available to nonmember depository 
institutions at the same fees charged to member banks”).  Therefore, even assuming 
§ 248a(c)(2)’s application to Federal Reserve Banks, nothing therein prevents them from 
denying a depository institution’s request for a master account.  
 
Considering PayServices’ wholesale reliance on U.S. Circuit Judge Robert Bacharach’s 
separate opinion in Fourth Corner, the above-referenced shortcomings in PayServices’ 
arguments correspondingly extend to that opinion and will not be re-hashed here.  But there are 
additional reasons for distinguishing Judge Bacharach’s opinion that are worth highlighting.  
First, Fourth Corner is out-of-circuit authority and therefore not controlling law in this district.  
Second, even if Fourth Corner was controlling, only Judge Bacharach’s opinion reached the 
merits, which was not substantively incorporated into the court’s ultimate per curiam decision.  
See, e.g., Maryland v. Wilson, 519 U.S. 408, 412-13 (1997) (statements within a concurrence do 
not “constitute[ ] binding precedent”); see also Banco San Juan, 2023 WL 7111182, at *8 
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MEMORANDUM DECISION AND ORDER - 19 
(“Judge Bacharach’s opinion is neither controlling (even in the Tenth Circuit), nor persuasive.”) 
(emphasis added).  Third, Judge Bacharach’s separate opinion was issued prior to the Board of 
Governors’ August 2022 Guidelines, which squarely contradict his reasoning.  See Fourth 
Corner, 861 F.3d at 1070-71 (Judge Bacharach commenting on the Board of Governors’ 
interpretation of the MCA “before this litigation”).  Finally, Judge Bacharach’s separate opinion 
preceded § 248c(b)(1)(B)’s December 2022 enaction.  See Banco San Juan, 2023 WL 7111182, 
at * 8 (“And Judge Bacharach in his 2017 opinion did not have the advantage of Congress’s 
December 23, 2022 statute, that explicitly acknowledged that the Board was required to maintain 
a database of Master Accounts rejected by Federal reserve banks.”) (citing § 248c(b)(1)(B)). 
 
At bottom, § 342 makes clear that Federal Reserve Banks are authorized to accept 
deposits, and thus open master accounts.  Critically, however, they are not required to do so.  
Nothing in § 248a(c)(2) upends this discretion.  Otherwise, Federal Reserve Banks would oddly 
be forced to open master accounts, without regard to the risks posed to the financial system, yet 
allow them to reject every deposit into those same master accounts.  Such an interpretation 
makes little sense.  A better reading of these statutes is that (i) Federal Reserve Banks have 
discretion to receive deposits by granting a master account under § 342, and that (ii) nonmember 
master account holders then have access to the services covered by the Board of Governors’ fee 
schedule at the same prices available to member master account holders under § 248a(c)(2).  The 
predicate discretion under § 342 precludes each of PayServices’ claims against FRBSF. 
 
FRBSF’s Motion to Dismiss is granted in this respect. 
 B. 
Each of PayServices’ Claims Must Alternatively Be Dismissed Because FRBSF Is  
Not an Agency of the Federal Government 
 
 
The success of PayServices’ APA, Mandamus Act, and Due Process claims also depends 
on whether FRBSF is a federal agency.  See 5 U.S.C. § 702 (APA allows judicial review for 
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MEMORANDUM DECISION AND ORDER - 20 
persons “suffering legal wrong because of agency action, or adversely affected or aggrieved by 
agency action”); 28 U.S.C. § 1361 (“The district courts shall have original jurisdiction of any 
action in the nature of mandamus to compel an officer or employee of the United States or any 
agency thereof to perform a duty owed to the plaintiff.”); Bingue v. Prunchak, 512 F.3d 1169, 
1174 (9th Cir. 2008) (“The Fifth Amendment’s due process clause only applies to the federal 
government.”).  FRBSF and PayServices agree that, to qualify as an agency under these theories, 
an entity must “exercise substantial independent authority” on behalf of the government or, in 
other words, be the “center of gravity in the exercise of administrative power.”  See Mem. ISO 
MTD at 15 (Dkt. 22-1) (quoting Dong v. Smithsonian Inst., 125 F.3d 877, 881-82 (D.C. Cir. 
1997)); Opp. to MTD at 10 (Dkt. 23) (same); compare with 5 U.S.C. § 701(b)(1) (APA defines 
“agency” as an “authority of the Government of the United States.”).  They predictably depart, 
however, on the ultimate question of whether Federal Reserve Banks meet this standard.  
Compare Mem. ISO MTD at 15-18 (Dkt. 22-1), with Opp. to MTD at 9-12 (Dkt. 23).   
 
Describing Federal Reserve Banks’ role within the Federal Reserve System, PayServices 
contends that, “as an instrumentality of the federal government,” they are inescapably 
governmental agencies subject to judicial review under the APA.  Opp. to MTD at 9-12 (Dkt. 
23); see also Compl. at ¶¶ 32, 80, 81 (Dkt. 1).  It is true that Federal Reserve Banks are integral 
components of the Federal Reserve System, such that it can legitimately be argued that they are 
federal instrumentalities.  See United States ex rel. Kraus v. Wells Fargo & Co., 943 F.3d 588, 
592 (2d. Cir. 2019) (Federal Reserve Banks “are instrumentalities of the federal government and 
the operating arms of its central bank.”).  But this characterization does not ipso facto make them 
government agencies.  This is especially true when “Congress has gone out of its way to 
formally separate the [Federal Reserve Banks] from the government”; “[t]he [Federal Reserve 
Banks] are not part of any executive department or agency”; Federal Reserve Banks do not 
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MEMORANDUM DECISION AND ORDER - 21 
“have the authority to promulgate regulations with the force and effect of law”; and “Congress 
has considered the status of the [Federal Reserve Banks] on multiple occasions and decided not 
to convert them formally into government agencies.”  Id. at 597-98.  Indeed, “many financial 
institutions are . . . considered federal instrumentalities, without attaining the status of 
government agencies within the meaning of federal procedural rules.”  In re Hoag Ranches, 846 
F.2d 1225, 1227 (9th Cir. 1988) (confronting whether a credit association is a federal agency 
under Federal Rule of Appellate Procedure 4(a)(1)). 
Federal Reserve Banks are more accurately described as private corporations, owned by 
their member commercial banks.  Supra (citing 12 U.S.C. § 341 (“Upon the filing of the 
organization certificate with the Comptroller of the Currency a Federal reserve bank shall 
become a body corporate[.]”)); see also, e.g., U.S. Shipping Bd. Emergency Fleet Corp. v. W. 
Union Tel. Co., 275 U.S. 415, 425-26 (1928) (“Instrumentalities like national banks or the 
federal reserve banks, in which there are private interests, are not departments of the 
government.  They are private corporations in which the government has an interest.”) 
(emphasis added); Kraus, 943 F.3d at 597 (“This separation from general government dates to 
the founding of the Fed in 1913 when Congress, following other major advanced economies, 
decided to leave governance of money and credit, at least in part, in private hands. . . .  [T]he 
legislative history of the FRA suggests that Congress intended the [Federal Reserve Banks] to 
serve the interests of, but stand apart from, the sovereign.”) (internal quotation marks omitted) 
(citing H.R. Rep. No. 69, 63d Cong., 1st Sess., at 18 (1913) (describing the Federal Reserve 
System’s structure as consisting of “a combination of public and private characteristics”)).   
Additionally, while Federal Reserve Banks operate with policy oversight by the Board of 
Governors (a recognized agency of the federal government), that does not convert Federal 
Reserve Banks into government agencies.  To the contrary, their unique statutory authorizations 
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MEMORANDUM DECISION AND ORDER - 22 
and control by their own board of directors sets them apart.  See 12 U.S.C. § 301 (Federal 
Reserve Banks’ “shall be conducted under the supervision and control of a board of directors” 
who “shall perform the duties usually appertaining to the office of directors of banking 
associations[.]”); id. at §§ 302, 304-305 (majority of Federal Reserve Banks’ board of directors 
elected not by the Board of Governors, but by commercial banks); see also Scott v. Fed. Rsrv. 
Bank of Kansas City, 406 F.3d 532, 535 (8th Cir. 2005) (“The Bank is a private, independent 
entity independently run by its own board of directors.  It is not run by the Federal Reserve 
Board of Governors or any other part of the executive branch.”).  A Federal Reserve Bank’s 
authority to issue master accounts, without more, does not upset this distinction.  See Dong, 125 
F.3d at 881 (“that an organization makes decisions does not always mean that it is a government 
agency”) (internal quotation marks omitted).  It is simply a prescribed function of Federal 
Reserve Banks within the Federal Reserve System, not a reflection of “substantial independent 
authority” on behalf of the federal government or the “center of gravity” in the exercise of its 
administrative power.  
For this reason, the Court disagrees with PayServices’ argument that Federal Reserve 
Banks are governmental agencies given that the Board of Governors has delegated to them the 
authority to grant master accounts.  Opp. to MTD at 10-12 (Dkt. 23) (citing 12 C.F.R. § 265.20; 
Lee Constr. Co. v. Fed. Rsrv. Bank of Richmond, 558 F. Supp. 165 (D. Md. Aug. 6, 1982)); see 
also Compl. at ¶¶ 6, 7, 79, 80 (Dkt. 1).  Significantly, however, the portion of the FRA 
discussing functions delegated to Federal Reserve Banks makes no reference to deposit accounts.  
See 12 C.F.R. § 265.20.  This is because Federal Reserve Banks already have this authority 
under § 342 (supra); that is, the Board of Governors does not have this authority to delegate 
away.  See Banco San Juan, 2023 WL 7111182, at *9-10 (distinguishing Lee, stating: “But 
unlike in Lee, the Board does not determine whether the FRBNY may open or terminate a 
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MEMORANDUM DECISION AND ORDER - 23 
Master Account.  Instead, the statute authorizes the FRBNY to use its discretion to make this 
decision. . . .  The FRA provides the FRBNY with discretion to open or terminate Master 
Accounts.”) (citing 12 U.S.C. § 342).    
In sum, despite the lack of controlling precent in the Ninth Circuit on the matter, the 
Court nonetheless concludes that Federal Reserve Banks are not agencies of the federal 
government in this setting.  The recognized principles on this point confirm as much to the 
Court’s satisfaction, as well as authority within the Ninth Circuit holding that Federal Reserve 
Banks are not federal agencies under a different statutory framework.  See Lewis, 680 F.2d at 
1241 (affirming district court’s dismissal for lack of subject matter jurisdiction, stating: 
“Examining the organization and function of the Federal Reserve Banks, and applying the 
relevant factors, we conclude that the Reserve Banks are not federal instrumentalities for 
purposes of the [Federal Tort Claims Act], but are independent, privately owned and locally 
controlled corporations.”).  In Lewis, the Ninth Circuit was persuaded that Federal Reserve 
Banks were not federal agencies owing to its historically intentional detachment from the federal 
government itself:   
It is evident from the legislative history of the Federal Reserve Act that Congress 
did not intend to give the federal government direction over the daily operations of 
the Reserve Banks: 
 
It is proposed that the Government shall retain sufficient power over 
the reserve banks to enable it to exercise a direct authority when 
necessary to do so, but that it shall in no way attempt to carry on 
through its own mechanism the routine operations and banking which 
require detailed knowledge of local and individual credit and which 
determine the funds of the community in any given instance.  In other 
words, the reserve-bank plan retains to the Government power over the 
exercise of the broader banking functions, while it leaves to individuals 
and privately owned institutions the actual direction of routine. 
 
Id. (quoting H.R. Rep. No. 69, 63d Cong., 1st Sess., at 18-19 (1913)); see also id. at 1241-43 
(discussing distinctness of Federal Reserve Banks).  The Court adopts this same line of reasoning 
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MEMORANDUM DECISION AND ORDER - 24 
to find that, on balance, Federal Reserve Banks are not an agency of the federal government for 
the purposes of PayServices’ claims against FRBSF. 
 
FRBSF’s Motion to Dismiss is granted in this alternate respect. 
C. 
PayServices’ APA Claim Must Alternatively Be Dismissed Because FRBSF’s  
Decision to Deny PayServices’ Master Account Request Was Not Arbitrary or  
Capricious 
 
 
Under the APA, an agency action must be upheld unless it is “arbitrary, capricious, an 
abuse of discretion, or otherwise not in accordance with law.”  5 U.S.C. § 706(2)(A).  A decision 
is arbitrary or capricious “‘if the agency has relied on factors which Congress has not intended it 
to consider, entirely failed to consider an important aspect of the problem, offered an explanation 
for its decision that runs counter to the evidence before the agency, or is so implausible that it 
could not be ascribed to a difference in view or the product of agency expertise.’”  Providence 
Yakima Med. Ctr. v. Sebelius, 611 F.3d 1181,1190 (9th Cir. 2010) (quoting Motor Vehicle Mfrs. 
Ass’n of the U.S., Inc. v. State Farm Mut. Auto. Ins. Co., 463 U.S. 29, 43 (1983)).  The 
“touchstone of ‘arbitrary [or] capricious’ review under the APA is ‘reasoned decision-making.’”  
Altera Corp. & Subsidiaries v. Comm’r of Internal Revenue, 926 F.3d 1061, 1080 (9th Cir. 2019) 
(quoting Motor Vehicle Mfrs. Ass’n, 463 U.S. at 52).  Courts sustain an agency action if the 
agency has “examine[d] the relevant data and articulate[d] a satisfactory explanation for its 
action including a ‘rational connection between the facts found and the choice made.’”  Id. 
(quoting Motor Vehicle Mfrs. Ass’n, 463 U.S. at 43) (internal quotation marks omitted)).  Courts 
are “highly deferential” to the agency’s decision, Providence Yakima, 611 F.3d at 1190, and are 
not to “substitute its judgment for that of the agency.”  J & G Sales Ltd. v. Truscott, 473 F.3d 
1043, 1051 9th Cir. 2007).  “[C]ourts will ‘uphold a decision of less than ideal clarity if the 
agency’s path may reasonably be discerned.’”  Id. at 1052 (quoting Motor Vehicle Mfrs. Ass’n, 
463 U.S. at 43). 
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MEMORANDUM DECISION AND ORDER - 25 
 
PayServices alleges that FRBSF’s decision to deny its master account request was 
arbitrary or capricious because FRBSF was required to issue the master account under the FRA.  
See Compl. at ¶¶ 84, 87-88 (Dkt. 1) (“Congress created one law – the Federal Reserve Act – and 
that is the only law of the land that regulates the FRBSF. . . .  Section 248a(c)(2) requires that ‘all 
Federal Reserve bank services . . . shall be available to nonmember depository institutions’ [ ] 
and the use of those services requires a master account.”) (emphasis in original).  But as already 
stated, § 342 – not § 248a(c)(2) – applies to master account requests.  Supra.  Therefore, to the 
extent that PayServices’ APA-related claim depends on § 248a(c)(2)’s application as a matter of 
law to requests for master accounts, it necessarily falls short and must be dismissed. 
 
And while PayServices alleges that FRBSF denied its master account request using the 
Board of Governors’ August 2022 Guidelines (Compl. at ¶¶ 78, 85 (Dkt. 1)), it does not plead 
any facts showing that FRBSF’s decision was inconsistent with them.  Absent any allegation that 
FRBSF failed to follow the Guidelines, there is nothing anchoring PayServices’ APA claim.  See 
El Rescate Legal Servs., Inc. v. Exec. Office of Immigration Review, 959 F.2d 742, 753 (9th Cir. 
1991) (“There no right to sue for a violation of the APA in the absence of a ‘relevant statute’ 
whose violation ‘forms the legal basis for [the] complaint.’”) (quoting Lujan v. Nat’l Wildlife 
Fed’n, 497 U.S. 871, 883 (1990)).10  PayServices’ disagreement with FRBSF’s decision (as 
opposed to the process involved) does not itself make that decision arbitrary or capricious.      
FRBSF’s Motion to Dismiss is granted in this alternate respect. 
 
10  PayServices attempts to “add meat to the bone” in this respect by attaching the 
Declaration of Lionel Danenberg (Dkt. 23-1) as an attachment to its opposition to FRBSF’s 
Motion to Dismiss.  As a general rule, courts “may not consider material beyond the complaint in 
ruling on a Rule 12(b)(6) motion.”  Intri-Plex Techs., Inc. v. Crest Group, Inc., 499 F.3d 1048, 
1052 (9th Cir. 2007).  Because the Court finds PayServices’ APA claim lacking for multiple 
reasons, it will grant FRBSF’s Motion to Strike (Dkt. 26) rather than accept the Declaration and 
convert FRBSF’s Motion to Dismiss into a motion for summary judgment.     
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MEMORANDUM DECISION AND ORDER - 26 
D. 
PayServices’ Due Process Claim Must Alternatively Be Dismissed Because There 
Were No Alleged Denials of Procedural Protections 
 
PayServices alleges that it has a property interest in a master account and that FRBSF’s 
denial of PayServices’ master account request violates its right to procedural and substantive due 
process under the Fifth Amendment to the U.S. Constitution.  Compl. at ¶¶ 100-103 (Dkt. 1).  
But PayServices does not have a legitimate claim of entitlement to a master account.  Supra.  
Therefore, PayServices’ allegation of a procedural due process violation is without merit.  See 
Brewster v. Bd. of Educ. of Lynwood Unified Sch. Dist., 149 F.3d 971, 982 (9th Cir. 1998) 
(Procedural due process claims have two elements: (i) a deprivation of a protected property 
interest; and (ii) a “denial of adequate procedural protections”) (emphasis added).   
As well, PayServices’ claim to a master account is not a fundamental right under the U.S. 
Constitution.  See Merrill v. Cnty. of Madera, 2013 WL 1326542, at *4 (E.D. Cal. Mar. 29, 
2013) (“Substantive due process protection is usually reserved for the vindication of fundamental 
rights, such as marriage, family, procreation, and bodily integrity.”) (citing Albright v. Oliver, 
510 U.S. 266, 272 (1994)).  Therefore, PayServices’ substantive due process violation is also 
without merit. 
 
In any event, FRBSF separately argues that, even if PayServices’ claim to a master 
account was a protected property interest, PayServices still has not been denied any procedural 
protections and that, as a result, its Due Process claim must be dismissed for this alternate 
reason.  Mem. ISO MTD at 20 (Dkt. 22-1) (citing Pinnacle Armor, Inc. v. United States, 648 
F.3d 708, 717 (9th Cir. 2011) (“The Due Process Clause, however, does not require that the 
agency grant a formal hearing.  All that is required before a deprivation of a protected interest is 
notice and opportunity for hearing appropriate to the nature of the case.”) (internal quotation 
marks omitted) (emphasis in original)).  To that end, FRBSF notes that PayServices admits that it 
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MEMORANDUM DECISION AND ORDER - 27 
received two opportunities to meet with FRBSF, was permitted to submit written evidence, and 
received a written decision explaining the basis for FRBSF’s decision.  Id. (citing Compl. at 
¶¶ 16, 23-25, 43 (Dkt. 1)).  According to FRBSF, these protections are enough to satisfy the Due 
Process Clause.  Id.  On this record, the Court agrees.  See Pinnacle, 648 F.3d at 717 (dismissing 
Due Process claim when plaintiff “had ample opportunities to submit evidence both before and 
after the Notice was revoked” and the state actor “explained its decision . . . even if no formal 
administrative hearings took place”). 
 
FRBSF’s Motion to Dismiss is granted in this alternate respect.   
IV.  ORDER 
 
Based on the foregoing, IT IS HEREBY ORDERED that (i) FRBSF’s Motion to Dismiss 
Plaintiff’s Complaint for Declaratory and Injunctive Relief (Dkt. 22) is GRANTED; (ii) 
FRBSF’s Motion to Strike the Declaration of Lionel Danenberg (Dkt. 26) is GRANTED; and 
(iii) FRBSF’s Motion for Leave to File a Notice of Supplemental Authority (Dkt. 34) is 
GRANTED.  PayServices’ Complaint is dismissed with prejudice. 
 
 
 
 
 
 
DATED:  March 30, 2024 
 
                                              
 
 
 
 
 
________________________ 
 
 
 
 
 
Honorable Raymond E. Patricco 
 
 
 
 
 
Chief U.S. Magistrate Judge 
 
 
 
Case 1:23-cv-00305-REP   Document 42   Filed 03/30/24   Page 27 of 27

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