Core Argument - Custodia, a Wyoming-chartered crypto bank, has filed a petition with the Tenth Circuit Court of Appeals to reconsider the Federal Reserve's denial of its master account application, marking a significant escalation in a five-year legal battle [1] Group 1: Legal and Regulatory Concerns - The petition requests an en banc review to determine if regional Federal Reserve Banks can exercise unreviewable discretion over master account access for legally eligible institutions [2] - Custodia argues that the Tenth Circuit panel's 2-1 ruling conflicts with the Monetary Control Act, which mandates that payment services "shall be available" to nonmember depository institutions, suggesting an unconstitutional veto power over state banking charters [3] - The filing raises concerns about federalism, as it suggests the Fed is overriding Wyoming's decision to charter Custodia as a Special Purpose Depository Institution [4] Group 2: Impact on State Banking Framework - Without master account access, Custodia cannot utilize essential Federal Reserve payment services, which undermines its state-issued charter despite meeting all statutory eligibility requirements [4] - The petition states that when the Fed denies a master account to a state-chartered financial institution, it effectively vetoes a bank charter approved by state regulators, which threatens the state regulatory framework designed to attract digital asset companies [5] Group 3: Constitutional Implications - Custodia's legal team argues that if regional Reserve Bank presidents have unreviewable discretion over master accounts, they act as "Officers of the United States" with significant executive authority without proper constitutional appointment [6] - The selection process for Federal Reserve Bank presidents, which involves private bank directors and the Board of Governors, is claimed to violate the Appointments Clause if these officials exercise discretionary power [7] Group 4: Judicial Disagreement - The petition highlights a growing disagreement among Tenth Circuit judges regarding statutory interpretation, indicating a deep judicial split [8]