In its response, Ripple listed four main suggested improvements: restricted access to the Federal Reserve's discount window, offering competitive interest rates, changing the fixed USD 500 million limit to a flexible limit based on ratios, and adding pre-funded functionality. Ripple Labs Submits Response to the Federal Reserve on the Proposed Payment Account Prototype – Crowdfund Insider
@Ripple Labs has submitted a detailed response to the U.S. Federal Reserve’s request for feedback on a proposed payment account prototype that would allow non-bank institutions—such as stablecoin issuers—to maintain direct accounts with the central bank.
In its submission, Ripple outlined four key proposed enhancements: limited access to the Federal Reserve’s discount window, the provision of competitive interest rates, the replacement of the static USD 500 million cap with a ratio-based dynamic limit, and the integration of pre-funded $ACH functionality.
The initiative is intended to enhance the efficiency, resilience, and security of the national financial infrastructure as the digital economy continues to evolve.

