OPINION AND ORDER The Narrow Bank USA Inc. (“TNB”) sued the Federal Reserve Bank of New York (“FRBNY”) seeking a declaratory judgment, injunctive relief, and a prompt hearing under Fed. R.Civ. P. 57. (Compl. at 24). TNB alleges that the FRBNY has refused to provide TNB with a”master account” despite its statutory obligation to do so. (Id. at 122-23). The FRBNY now moves to dismiss TNB’s complaint pursuant to Fed. R. Civ. P. 12(b)(1) for lack of subject matter jurisdiction, and pursuant to Fed. R. Civ. P. 12(b)(6) for failure to state a claim. (ECF No. 20). For the reasons below, that motion is GRANTED on jurisdictional grounds. I. Federal Reserve System The Federal Reserve System is the Nation’s central bank. It consists of twelve Federal Reserve banks across the country, the Board of Governors, and the Federal Open Market Committee (“FOMC”). (ECF No. 21 at 3; ECF No. 24 at 10). The Board of Governors “is a United States government agency composed of seven members appointed by the President and confirmed by the Senate.” (ECF No. 45 at 9). Pursuant to the Federal Reserve Act, the Board and the FOMC are charged “with conducting monetary policy to achieve the goals of ‘maximum employment, stable prices, and moderate long-term interest rates.’” (Id.) (citing 12 U.S.C. §225a). “The Board has statutory authority to promulgate rules implementing its powers under the FRA and other statutes, and that authority may not be delegated.” (Id.) (citing 12 U.S.C. §§248(i)). As long as they are “reasonable and consistent with legislative intent[,]” “ [t]he Board’s interpretation[s] of federal banking statutes it implements [are] entitled to judicial deference[.]” (Id.). The FRBNY is one of the twelve Federal Reserve banks operating in the United States. Like the Board, Federal Reserve banks “serve the public interest by providing the nation with a stable financial situation and by setting and implementing monetary policy.” (ECF No. 21 at 11). Part of the way in which the banks implement monetary policy is through reserves. Reserves are “liquid assets that depository institutions maintain at Federal Reserve banks, including in the form of deposits held in accounts referred to as ‘master accounts.’” (Id. at 13) (citing Federal Reserve Operating Circular No. 1 (Account Relationships) (“OC 1″) at 1.0 (describing master accounts), available at https://frbservices.org/assets/resources/rules-regulations/020113-operating-circular-1.pdf). “A master account is, put simply, a bank account for banks. It gives depository institutions access to the Federal Reserve System’s services, including its electronic payments systems.…Without such access, a depository institution is nothing more than a vault.” Fourth Corner Credit Union v. Fed. Reserve Bank of Kansas City, 861 F.3d 1052, 1053 (10th Cir. 2017) (Moritz, J.) (internal quotation marks omitted). The Federal Reserve requires that depository institutions maintain a minimum amount of reserves against certain of their liabilities (“required reserves”). (ECF No. 24 at 12; ECF No. 21 at 13) (citing 12 U.S.C. §461; 12 C.F.R. pt. 204). “However, depository institutions may elect to maintain reserves beyond the required amount, which are referred to as excess reserves.” (ECF No. 21 at 5; see ECF No. 24 at 12). The rate at which depository institutions lend excess reserves to one another overnight is known as the federal funds rate. (ECF No. 21 at 13; Compl. at 83). The federal funds rate is a benchmark for many other private market interest rates. (ECF No. 21 at 13; Compl. at 85). The Federal Reserve uses the policy tools at its disposal to influence the federal funds rate. One critical tool is the Interest on Excess Reserves Rate (“IOER rate”) — “the rate that Federal Reserve Banks pay to depository institutions on excess reserves.” (ECF No. 21 at 13; see Compl. at 87). The higher the IOER, the more attractive maintaining excess reserves becomes to institutions. The supply of reserves in turn influences the federal funds rate and “helps the Federal Reserve System achieve its broader employment and inflation goals.” (ECF No. 21 at 13-14; Compl. at
87-91, 108). II. Facts TNB began the process of opening an account with the FRBNY in August 2017. (Compl. at 5). TNB has not opened for business yet. Its board of directors and management have spent over two years preparing for its opening. (Compl. at 3). TNB stands for “the narrow bank,” which describes the structure of the business TNB plans to establish. “TNB’s sole business will be to accept deposits only from the most financially secure institutions, and to place those deposits into TNB’s Master Account at the FRBNY, thus permitting depositors to earn higher rates of interest than are currently available to nonfinancial companies and consumers for such a safe, liquid form of deposit.” (Id. at 2). TNB will earn a “modest profit” by paying its depositors interest at a “slightly lower rate.” (Id. at 44). To carry out its business, TNB needs access to the Federal Reserve payments system, which is available only to depository institutions with a master account. (Id. at 4). To operate as a bank and obtain a master account at a Federal Reserve bank, TNB needed to obtain a state or federal charter. TNB went to the Connecticut Department of Banking (“CTDoB”) to obtain a state charter. “TNB planned to forgo FDIC insurance and therefore would not be regulated by the FDIC. Instead, the CTDoB would be TNB’s chartering authority and regulator, as provided under relevant state and federal law.” (Id. at 49). The CTDoB issued TNB a temporary Certificate of Authority (“CoA”) in August 2017. (Id. at 50). The CoA “set forth several conditions TNB was required to meet before the CTDoB would issue a final CoA.” (Id.) One of these conditions was that TNB produce evidence that the FRBNY would open a master account for TNB.” (Id. at 52). According to TNB, the master account application process is typically straightforward and short. The applicant completes a one-page form agreement and waits “no more than one week” for a response. (Id. at 5). The agreement form provides that “[p]rocessing may take 5-7 business days” and that the applicant should “contact the Federal Reserve Bank to confirm the date that the master account will be established.” (Id.; see id. at 54) To complete the form, however, TNB first needed to obtain an American Bankers Association (“ABA”) routing number issued by Accuity, the ABA’s official Registrar of Routing Numbers.” (Id. at 55). “The only eligibility requirements” for an Accuity routing number “are that the applicant be chartered and eligible to maintain an account at a Federal Reserve Bank.” (Id. at 56) (internal quotation marks omitted). “The Accuity application states that it takes approximately two weeks to process, and will be forwarded to the Federal Reserve in the applicant’s district for verification.” (Id. at 57) (internal quotation marks and brackets omitted). TNB submitted its application to Accuity in August 2017 and Accuity forwarded it to the FRBNY for verification. (Id. at
