[locopati]

Has no authority but is taking authoritorial actions. Right. He's not a federal employee afaik as he hasn't passed any of the requisite checks or been approved by the Senate.

[ty6853]

I do not think you need a confirmation nor a commission to hold office to access payment systems.

[piva00]

Access payment systems is not the objective[0].

[0] https://www.ft.com/content/27ba0a6a-0d9b-4e08-8329-730b581c0...