In Custodia’s criticism, attorneys for the Wyoming-based financial institution argued {that a} grasp account was “very important to Custodia’s potential to function successfully and effectively,” and that the Fed’s continued waffling on the choice was detrimental to Custodia’s clients – and, moreover, indicated a “black field bureaucratic course of with no clear guidelines” that allowed it to “act in full secrecy, at any time when and nonetheless they select.”