In just four days, two major stablecoin giants launched critical compliance efforts within the U.S. financial regulatory system.

Written by: Pzai, Foresight News

On June 30, stablecoin issuer Circle submitted an application for a national trust bank charter to the Office of the Comptroller of the Currency (OCC) and plans to establish a national trust bank in the U.S.; on July 2, Ripple followed suit by submitting a national bank charter application, having previously applied for a Federal Reserve master account through its subsidiary Standard Custody, intending to directly custody RLUSD reserves. Within just four days, these two stablecoin giants initiated key compliance efforts in the U.S. financial regulatory system.

As one of the important financial strategies during the Trump administration, the payment of stablecoins aligns with the potential demand for U.S. Treasury bonds under the dollar system. In the current rapid establishment of the stablecoin industry, why does the stablecoin sector favor U.S. licenses?

GENIUS Act Catalyst: Federal License as a Lifeline

The core driving force behind this licensing battle is the passage of the GENIUS Act (Guiding and Establishing National Innovation for US Stablecoins Act) by the U.S. Senate in mid-June. This act systematically stipulates for the first time that stablecoin issuers must become "licensed payment stablecoin issuers" and must meet federal or state regulatory requirements.

Two key provisions in the act directly drive issuers' licensing applications:

Custodial Asset Segregation Requirements

• The reserve assets of compliant stablecoins must be independently custodied, prohibiting commingling with the issuer's own funds, and can only be invested in cash, short-term U.S. Treasury bonds, and other highly liquid assets, eliminating re-pledging or leverage operations.

• In the event of issuer bankruptcy, reserve assets are prioritized for repayment to token holders as trust property, taking precedence over general creditors.

Financial Institution Qualification Thresholds

• Issuers must hold a federal (OCC/Federal Reserve/FDIC) or "substantially equivalent" state license; unlicensed entities are prohibited from operating in the U.S.

• Scale-based Regulation: Stablecoin issuance of ≤$10 billion can opt for a state license; exceeding this limit mandates a federal license upgrade, or the issuer must shrink its balance sheet.

The GENIUS Act positions stablecoins as payment tools rather than investment products through its designs of "de-interesting" (prohibiting interest payments to users) and "technical backdoors" (mandating built-in freeze/destroy functions), while also providing compliance intervention channels for law enforcement agencies.

As stablecoin issuers accelerate their integration into the mainstream financial system, the divide between state and federal regulatory frameworks is profoundly reshaping the competitive landscape of the industry. The fragmented regulation of state licenses has led issuers into compliance dilemmas—taking Ripple's RLUSD as an example, even after passing the stringent BitLicense review by the New York State Department of Financial Services (NYDFS), it still needs to spend months applying for licenses in states like California and Texas, with each state requiring application fees ranging from $50,000 to $200,000 and the establishment of localized compliance teams. The regulatory discrepancies between states further result in operational inefficiencies: the frequency of reserve asset audits varies from quarterly to semi-annually, with significant differences in disclosure standards, and the regulatory differences between states force stablecoin business designs to "settle for the lower standard."

Ripple's current OCC application takes this a step further. It aims to layer federal OCC regulation on top of the existing NYDFS regulatory framework, targeting a "state + federal" dual regulatory structure. If its subsidiary obtains a Federal Reserve master account, RLUSD reserves will be directly held within the Federal Reserve system. Having reserve assets under federal oversight significantly reduces the costs of cross-domain compliance, and Ripple CEO Brad Garlinghouse has stated that this will establish a "new benchmark of trust" for the stablecoin market.

The 2023 Silicon Valley Bank (SVB) crisis caused Circle to be trapped with $3.3 billion in reserves at SVB, leading to panic in the market and a brief de-pegging of USDC, nearly collapsing market confidence. The core purpose of Circle applying for a national trust bank charter is to gain the qualification to self-custody its reserves, eliminating the need to rely on commercial banks for custody and completely removing the risk of a "bank run contagion."

The OCC not only enables nationwide one-time access but also reshapes the industry ecosystem through a threefold mechanism: stablecoin reserves will be directly held in the central bank system, completely eliminating the risk of commercial bank failures and achieving real-time settlement; it also grants issuers SEC-certified "qualified custodian" status, allowing them to custody tokenized stocks and bonds for institutional clients, enabling Circle to participate in the digital asset custody market; more importantly, the OCC automatically covers state money transmission licenses, uniformly applying its risk-weighted capital standards, avoiding regulatory universality issues arising from differences in capital adequacy ratios across states.

The pursuit of bank licenses by stablecoin issuers is not a sudden effort but a concentrated explosion of years of compliance exploration. Taking Circle as an example, it successfully obtained the first electronic money institution (EMI) license under the EU MiCA framework on July 2, 2024, allowing it to compliantly issue USDC and euro stablecoin EURC in 27 countries. In the Middle East, Circle has obtained a principle license from Abu Dhabi MSB, targeting key on-chain settlement scenarios for oil dollar transactions.

The high-threshold licensing system established by local regulatory agencies has created a strong barrier for this high-cost compliance layout; for instance, the high capital requirements (350,000 euros) and operational reserves mandated by the EU MiCA have led many small and medium-sized issuers to exit, while Circle has been able to seize the entry point into the stablecoin market in the EU, which has a population of 450 million, posing a significant competitive threat to its rivals.

As the licensing applications progress, the positioning of stablecoins has evolved from merely being a medium of exchange to becoming a core component of financial infrastructure. Circle's Chief Strategy Officer Dante Disparte stated that federal regulation will enable the company to become a "dollar on-chain executor," reshaping the global flow of dollars.

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