The Federal Reserve’s digital dollar “intermediary bank model” may undermine financial inclusion goals. By relying on commercial banks as intermediaries, it risks excluding unbanked populations who lack access to traditional banking due to costs, distrust, or geographic barriers. These banks may prioritize profitable customers, limiting outreach to underserved communities. The model’s compliance requirements, like identity verification, could further deter those wary of surveillance or unable to meet documentation standards. While intermediaries leverage existing infrastructure, they may not address the unique needs of the financially excluded, such as low-cost, offline-accessible options. A direct-access CBDC could better serve the unbanked, but the intermediated approach may reinforce existing inequities, falling short of universal financial inclusion. Congressional approval and careful design are critical to align with inclusion objectives.