Joint Status Report (July 31, 2025) — ALJ Recommended Order — PayServices v. FRBSF

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A joint status report filed July 31, 2025 in PayServices Bank v. Federal Reserve Bank of San Francisco, No. 24-2355, in the U.S. Court of Appeals for the Ninth Circuit, on appeal from the District of Idaho, No. 1:23-cv-00305-REP. It is filed under the Court's January 24, 2025 order directing status reports every 30 days until the administrative appeal is resolved. The report states that an Administrative Law Judge issued a Recommended Order on July 21, 2025 and an amended Recommended Order on July 23, 2025 in PayServices' challenge to the termination of its preliminary approval. PayServices states it intends to seek reconsideration by an August 6, 2025 deadline and has declined to give FRBSF copies of the recommended orders as not final. The report states the Idaho Department of Finance has not taken final agency action.

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No. 24-2355 
__________________________________________________________________ 
 
IN THE UNITED STATES COURT OF APPEALS 
FOR THE NINTH CIRCUIT 
 
 
PAYSERVICES BANK, 
 
Plaintiff-Appellant, 
 
v. 
 
FEDERAL RESERVE BANK OF SAN FRANCISCO, 
 
Defendant-Appellee. 
 
On Appeal from the United States District Court 
for the District of Idaho 
No. 1:23-cv-00305-REP 
Hon. Raymond E. Patricco, Jr. 
 
 
JOINT STATUS REPORT 
 
 
Jade A. Craig, Esq. 
Jade A. Craig, P.A. 
1048 S. Clearview Avenue, #3 
Tampa, Florida 33629 
Telephone: (813) 459-1309 
jade@jadeacraigpa.com 
 
Attorney for Appellant  
PayServices Bank 
Jonathan K. Youngwood   
Simpson Thacher & Bartlett LLP   
425 Lexington Avenue   
New York, NY 10017  
Telephone: (415) 455-3539 
jyoungwood@stblaw.com  
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco 
 
Case: 24-2355, 07/31/2025, DktEntry: 61.1, Page 1 of 4

INTRODUCTION 
In the Court’s Order entered on January 24, 2025 (Docket Entry No. 52.1), 
the Court directed the parties to “file a status report as to the status of the appeal by 
February 27, 2025 and every 30 days thereafter until the resolution of the 
administrative appeal.” In compliance with this directive, the parties state the 
following: 
1. 
Appellee Federal Reserve Bank of San Francisco (“FRBSF”) does not 
have access to the Idaho Office of Administrative Recommended Order or amended 
Recommended Order referenced below.  FRBSF requested copies of the 
recommended orders, which Appellant PayServices has declined to provide.  FRBSF 
is only aware of the below events through PayServices’ updates herein and has no 
other updates or information regarding the status of PayServices’ administrative 
appeal. 
2. 
The matter pending before the Idaho Office of Administrative Hearings 
challenging the termination of PayServices’ preliminary approval has progressed. A 
Recommended Order was issued by the Administrative Law Judge on July 21, 2025, 
followed by an amended Recommended Order issued on July 23, 2025. PayServices 
intends to file a Motion for Reconsideration of this Recommended Order based on 
newly available evidence that directly contradicts certain aspects of the 
recommendation. The deadline for filing that Motion is August 6, 2025. The Idaho 
Case: 24-2355, 07/31/2025, DktEntry: 61.1, Page 2 of 4

2 
 
Department of Finance has not issued a final order or taken final agency action. 
Thus, the matter remains pending and the administrative appeal is still undecided.  
3. 
PayServices has declined to provide copies of the original and amended 
Recommended Orders to FRBSF because they are not final orders or an “explanation 
provided by the Idaho Department of Finance,” which the Court has directed 
PayServices to provide in its January 24, 2025 Order “upon the resolution of 
PayServices’ administrative appeal.”  Providing them to FRBSF at this time would 
be premature. 
4. 
Any further updates in this matter will be provided via a status report 
which will be filed 30 days from today’s date. 
Date: July 31, 2025  
 
 
Jade A. Craig, P.A. 
 
s/ Jade A. Craig_______ 
Jade A. Craig 
 
Attorney for Appellant PayServices 
Bank 
 
 
Simpson Thacher & Bartlett LLP 
 
s/ Jonathan K. Youngwood____ 
Jonathan K. Youngwood 
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco  
 
 
 
 
 
 
 
 
 
Case: 24-2355, 07/31/2025, DktEntry: 61.1, Page 3 of 4

3 
 
CERTIFICATE OF FILING AND SERVICE 
 
 
I hereby certify that on this 31 day of July, 2025, I electronically filed the 
foregoing with the Clerk of Court for the United States Court of Appeals for the 
Ninth Circuit by using the appellate CM/ECF system. 
 
 
 
/s/ Jonathan K. Youngwood_____ 
Jonathan K. Youngwood 
Simpson Thacher & Bartlett LLP 
425 Lexington Avenue   
New York, NY 10017  
Telephone: (212) 455-2000 
jyoungwood@stblaw.com 
 
Attorney for Appellee Federal Reserve 
Bank of San Francisco 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Case: 24-2355, 07/31/2025, DktEntry: 61.1, Page 4 of 4

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