Original | Odaily Planet Daily (@OdailyChina)

Author | Ethan (@ethanzhangweb3)_

On December 12, 2025, the Office of the Comptroller of the Currency (OCC) in Washington, D.C., issued a notice conditionally approving five digital asset institutions—Ripple, Circle, Paxos, BitGo, and Fidelity Digital Assets—to transition into federally chartered national trust banks.

This decision did not trigger significant market fluctuations but is widely regarded in regulatory and financial circles as a watershed moment. For the first time, crypto companies, which have long operated on the fringes of the traditional financial system and frequently faced interruptions in banking services, are officially included in the U.S. federal banking regulatory framework under the identity of "banks."

The change was not sudden but was thorough enough. Ripple plans to establish the "Ripple National Trust Bank," while Circle will operate the "First National Digital Currency Bank." These names themselves clearly convey the signal released by regulators: businesses related to digital assets are no longer merely "high-risk exceptions" passively subjected to scrutiny but are allowed to enter the core of the federal financial system under clear rules.

This shift stands in stark contrast to the regulatory environment of a few years ago. Especially during the banking turmoil of 2023, the crypto industry found itself deeply mired in the so-called "de-banking" dilemma, being systematically cut off from the U.S. dollar settlement system. With the signing of the GENIUS Act by President Trump in July 2025, stablecoins and related institutions received a clear federal legal status for the first time, providing a systemic basis for the OCC's concentrated issuance of charters.

This article will explore four aspects: "What is a federal trust bank?", "Why is this license important?", "The regulatory shift in the Trump era," and "The responses and challenges from traditional finance," to clarify the institutional logic and real-world impact behind this approval. The core judgment is: The crypto industry is transitioning from being an "external user" reliant on the banking system to becoming part of the financial infrastructure. This not only changes the cost structure of payments and settlements but is also reshaping the definition of "bank" in the digital economy.

What is a "Federal Trust Bank"?

To understand the true significance of the OCC's approval, it is essential to clarify a commonly misunderstood issue: This does not mean that the five crypto companies have obtained a traditional "commercial bank license."

The OCC has approved the qualification of "national trust banks." This is a type of bank charter that has long existed in the U.S. banking system but primarily served business forms such as estate management and institutional custody in the past. Its core value lies not in "how much business it can conduct," but in the level of regulation and infrastructure status.

What Does Federal Chartering Mean?

In the U.S. dual banking system, financial institutions can choose to be regulated by state or federal governments. The two are not simply parallel in compliance intensity but have clear hierarchical differences in authority. A federal charter bank license issued by the OCC means that the institution is directly regulated by the Treasury Department and enjoys "federal priority," no longer needing to adapt to the regulatory rules of each state in terms of compliance and operations.

The legal foundation for this can be traced back to the National Bank Act of 1864. Over the following century and a half, this system has been an important institutional tool for forming a unified financial market in the U.S. This is particularly crucial for crypto companies.

Before this approval, whether Circle, Ripple, or Paxos wanted to operate compliantly across the United States, they had to apply for money transmission licenses (MTL) in all 50 states, facing a "puzzle-like" system with completely different regulatory standards, compliance requirements, and enforcement scales. This was not only costly but also severely limited the efficiency of business expansion.

After transitioning to federal trust banks, the regulatory subject shifts from state financial regulatory agencies to the OCC. For companies, this means a unified compliance path, a nationwide business passport, and a structural elevation of regulatory credibility.

Trust Banks, Not "Miniature Commercial Banks"

It is important to emphasize that federal trust banks are not equivalent to "full-service commercial banks." The five institutions approved this time are not allowed to accept public deposits insured by the FDIC, nor can they issue commercial loans. This is one of the core reasons traditional banking organizations (such as the Bank Policy Institute) have questioned this policy, arguing that it represents an "unequal balance of rights and obligations" for entry.

However, from the perspective of the business structure of crypto enterprises, such restrictions are highly compatible. For example, stablecoin issuers, whether Circle's USDC or Ripple's RLUSD, have their business logic built on 100% reserve asset backing. Stablecoins do not engage in credit expansion and do not rely on a fractional reserve lending model, thus avoiding the systemic risks associated with the "mismatch of deposit and loan terms" seen in traditional banks. Under this premise, introducing FDIC deposit insurance is neither necessary nor would it significantly increase compliance burdens.

More importantly, the core of the trust bank license lies in fiduciary responsibility. This means that licensed institutions are legally required to strictly separate customer assets from their own funds and prioritize customer interests. This is of great practical significance for the entire crypto industry, especially after the FTX incident involving the misappropriation of customer assets; asset segregation is no longer a company promise but a mandatory obligation under federal law.

From "Custodian" to "Payment Node"

Another layer of significance in this transformation is the critical shift in the regulatory interpretation of the business scope of "trust banks." OCC head Jonathan Gould has clearly stated that the new federal bank entry "provides consumers with new products, services, and sources of credit, ensuring that the banking system is vibrant, competitive, and diverse." This lays the policy foundation for accepting crypto institutions.

Within this framework, the "conversion" of Paxos and BitGo from state-level trusts to federal trust banks holds strategic value far beyond mere title changes. The core is that the OCC's system grants federal trust banks a key right: the qualification to apply for access to the Federal Reserve's payment system. Therefore, their true goal is not the title of "bank" but to compete for direct access to the central bank's core settlement system.

Taking Paxos as an example, although it had previously become a compliance benchmark under the strict regulation of the New York State Department of Financial Services, state licenses have inherent limitations: they cannot directly integrate into the federal payment network. The OCC's approval document clearly states that the newly converted entity can continue to engage in stablecoin issuance, asset tokenization, and digital asset custody. This formally acknowledges at the institutional level that the issuance of stablecoins and asset tokenization has become legitimate "banking business." This is not a breakthrough for individual companies but a substantive expansion of the functional scope of "banking."

Once fully implemented, these institutions are expected to connect directly to central bank payment systems like Fedwire or CHIPS, no longer needing to rely on traditional commercial banks as intermediaries. The leap from "managed asset managers" to "direct nodes in the payment network" is the most structurally significant breakthrough in this regulatory shift.

Why is This License Invaluable?

The true value of the federal trust bank license lies not in the identity of "bank" itself but in the potential it opens up—a direct pathway to the Federal Reserve's clearing system.

This is why Ripple CEO Brad Garlinghouse referred to this approval as "a huge step forward," while traditional banking lobby groups (BPI) expressed significant unease. For the former, it represents an enhancement of efficiency and certainty; for the latter, it means that the long-standing monopoly on financial infrastructure is being redistributed.

What Does Direct Access to the Federal Reserve Mean?

Prior to this, crypto companies have always been on the "periphery" of the U.S. dollar system. Whether Circle issues USDC or Ripple provides cross-border payment services, any final settlement involving dollars had to be completed through commercial banks as intermediaries. This model is known in financial terms as the "agency banking system." On the surface, it merely lengthens the process, but it fundamentally brings three long-standing issues that trouble the industry.

First is the uncertainty of survival rights. In recent years, the crypto industry has repeatedly faced unilateral service termination by banks. Once an agency bank withdraws, the fiat currency channels for crypto companies can be cut off in a very short time, leading to business stagnation. This is what the industry refers to as the risk of "de-banking."

Second is the cost and efficiency issue. The agency banking model means that every fund transfer must go through multiple layers of bank clearing, each accompanied by fees and time delays. This structure is inherently unfriendly to high-frequency payments and stablecoin settlements.

Third is settlement risk. Traditional banking systems generally adopt T+1 or T+2 settlement rhythms, during which funds in transit not only occupy liquidity but are also exposed to bank credit risk. During the collapse of Silicon Valley Bank in 2023, Circle had approximately $3.3 billion in USDC reserves briefly stranded in the banking system, an event that is still viewed as a cautionary tale for the industry.

The identity of a federal trust bank changes this structure. At the institutional level, licensed entities are qualified to apply for a Federal Reserve "master account." Once approved, they can directly access Fedwire and other federal-level clearing networks, completing real-time, irrevocable final settlements in the dollar system without relying on any commercial bank intermediaries.

This means that, in the critical area of fund clearing, institutions like Circle and Ripple are, for the first time, positioned at the same "system level" as JPMorgan Chase and Citibank.

Extreme Cost Advantages, Not Marginal Optimization

The reduction in payment costs associated with obtaining a master account is structural rather than marginal. The core principle is that direct access to the Federal Reserve payment system (such as Fedwire) completely bypasses the multi-layered intermediaries of traditional agency banks, thereby eliminating the corresponding intermediary fees and markups.

We can extrapolate based on industry practices and the Federal Reserve's 2026 public fee structure. After calculations, it was found that in high-frequency, large-amount scenarios such as stablecoin issuance and institutional payments, this direct connection model could reduce overall settlement costs by approximately 30%-50%. The cost reductions primarily stem from two aspects:

1. Direct rate advantages: The Federal Reserve's single transaction fee for large payments via Fedwire is significantly lower than the wire transfer quotes from commercial banks.
2. Structural simplification: It eliminates various fees, account maintenance costs, and liquidity management costs associated with agency banks.

Taking Circle as an example, its management of nearly $80 billion in USDC reserves faces enormous capital turnover daily. If a direct connection is achieved, the savings from just the payment channel fees could amount to hundreds of millions of dollars annually. This is not a minor optimization but a fundamental cost restructuring at the business model level.

Therefore, the cost advantages brought by obtaining master account qualifications are certain and substantial, directly translating into a core moat for stablecoin issuers in terms of rate competition and operational efficiency.

The Legal and Financial Attributes of Stablecoins Are Changing

When stablecoin issuers operate as federal trust banks, the attributes of their products also change. Under the old model, USDC or RLUSD were closer to "digital certificates issued by tech companies," with their security heavily reliant on the governance of the issuer and the robustness of partner banks. In the new structure, stablecoin reserves will be placed under the fiduciary system regulated by the OCC, achieving legal separation from the issuer's own assets.

This is not equivalent to central bank digital currency (CBDC), nor is there FDIC insurance, but under the combination of "100% full reserve + federal-level regulation + fiduciary responsibility," its credit rating is now significantly higher than that of most offshore stablecoin products.

The more practical impact lies in the payment layer. Taking Ripple as an example, its ODL (On-Demand Liquidity) product has long been constrained by bank operating hours and the opening rhythm of fiat channels. Once integrated into the federal clearing system, the switching between fiat and on-chain assets will no longer be limited by time windows, significantly enhancing the continuity and certainty of cross-border settlements.

Market Reactions Are Surprisingly Rational

Although this development is seen as a milestone in the industry, the market reaction has not been dramatic. Whether it is XRP or USDC-related assets, price changes have been relatively limited. However, this does not mean the value of the license is underestimated; it more likely indicates that the market has viewed it as a long-term institutional change rather than a short-term trading theme.

Ripple CEO Brad Garlinghouse defined this development as "the highest standard on the compliance path for stablecoins." He emphasized that RLUSD is now under dual regulation from both federal (OCC) and state (NYDFS) authorities, and directly challenged traditional banking lobby groups: "Your anti-competitive tactics have been seen through. You complain that the crypto industry does not follow the rules, but now we are under the direct regulatory standards of the OCC. What are you really afraid of?"

At the same time, Circle also pointed out in related statements that the national trust bank charter will fundamentally reshape institutional trust, enabling issuers to provide more fiduciary digital asset custody services to institutional clients.

The statements from both parties converge: From "being served by banks" to "becoming part of the banking system," crypto finance is entering a brand new phase. The federal trust bank license is not just a permit; it paves a safe pathway for institutional capital that has been hesitant due to compliance uncertainties to enter the crypto market.

The "Golden Age" of the Trump Era and the GENIUS Act

Looking back three to four years, it is hard to imagine that crypto companies could gain federal recognition as "banks" by the end of 2025. This transformation was not driven by technological breakthroughs but by a fundamental shift in the political and regulatory environment.

The return of the Trump administration and the implementation of the GENIUS Act have jointly paved the way for crypto finance to access the federal system.

From "De-banking" to Institutional Acceptance

During the Biden administration, the crypto industry was long subjected to a highly regulated and uncertain environment. Especially after the collapse of FTX in 2022, the regulatory tone shifted to "risk isolation," with the banking system being urged to distance itself from crypto businesses.

This phase was referred to internally in the industry as "de-banking," and some lawmakers described it as "Operation Choke Point 2.0." According to a subsequent investigation by the House Financial Services Committee, several banks cut ties with crypto companies under informal regulatory pressure. The successive exits of Silvergate Bank and Signature Bank exemplified this trend.

The regulatory logic at the time was clear: It is better to isolate crypto risks than to struggle to regulate them.

This logic underwent a fundamental reversal in 2025.

Trump publicly supported the crypto industry multiple times during his campaign, emphasizing the need to make the U.S. a "global center for crypto innovation." After regaining power, crypto assets were no longer simply viewed as sources of risk but were incorporated into broader financial and strategic considerations.

The key shift was that stablecoins began to be seen as extensions of the U.S. dollar system. On the day the GENIUS Act was signed, the White House explicitly stated that regulated dollar stablecoins would help expand demand for U.S. Treasury bonds and strengthen the international position of the dollar in the digital age. This effectively redefined the role of stablecoin issuers in the U.S. financial system.

The Institutional Role of the GENIUS Act

In July 2025, Trump signed the GENIUS Act. The significance of this act lies in its establishment of a clear legal identity for stablecoins and related institutions at the federal level for the first time. The act explicitly allows non-bank institutions to serve as "qualified payment stablecoin issuers" under federal regulation, provided they meet certain conditions. This provides a regulatory entry point for companies like Circle and Paxos, which were previously outside the banking system.

More importantly, the act imposes strict requirements on reserve assets: stablecoins must be 100% fully backed by highly liquid assets such as cash in U.S. dollars or short-term U.S. Treasury bonds. This effectively eliminates the space for algorithmic stablecoins and high-risk configurations, aligning closely with the "no deposits, no loans" model of trust banks.

Additionally, the act establishes priority repayment rights for stablecoin holders. Even if the issuing institution goes bankrupt, the related reserve assets must be prioritized for redeeming stablecoins. This provision significantly reduces regulatory concerns about "moral hazard" and enhances the credibility of stablecoins at the institutional level.

Within this framework, the OCC's issuance of federal trust bank licenses to crypto companies becomes a regulatory compliance implementation that is logical and expected.

The Defense of Traditional Finance and Future Challenges

For the crypto industry, this represents a long-overdue institutional breakthrough; for Wall Street's vested interests, it feels more like a necessary counterattack against an invasion of territory. The OCC's approval of five crypto institutions to transition into federal trust banks did not receive unanimous applause; instead, it quickly triggered a fierce defense from traditional banking alliances represented by the Bank Policy Institute (BPI). This "war between new and old banks" has only just begun.

BPI's Fierce Counterattack: Three Core Accusations

The BPI represents the interests of giants like JPMorgan Chase, Bank of America, and Citigroup. Immediately after the OCC announced its decision, its executives issued sharp criticisms, with core arguments directly targeting the deep-seated conflicts in regulatory philosophy.

First is the accusation of "regulatory arbitrage" under the guise of trust licenses. The BPI pointed out that these crypto institutions applying for "trust" licenses are merely masking their actual engagement in core banking activities such as payments and settlements, with systemic importance even exceeding that of many mid-sized commercial banks.

However, through trust licenses, their parent companies (such as Circle Internet Financial) cleverly evade the consolidated supervision required of "bank holding companies" by the Federal Reserve. This means regulators have no authority to review the parent company's software development or external investments—if a coding flaw in the parent company leads to losses in bank assets, this creates a significant risk exposure in a regulatory blind spot.

Second is the violation of the sacred principle of "separation of banking and commerce." The BPI warned that allowing tech companies like Ripple and Circle to own banks effectively breaks down the firewall preventing industrial giants from using bank funds for their own benefit. Traditional banks are further dissatisfied with the unfair competition: tech companies can leverage their monopolistic advantages in social networks and data flows to crowd out banks without having to fulfill the community reinvestment obligations that traditional banks must meet.

Finally, there is panic over systemic risk and the lack of safety nets. Since these new trust banks do not have FDIC insurance backing, if market panic leads to stablecoins losing their peg, traditional deposit insurance cannot provide a buffer. The BPI argues that this unprotected liquidity depletion could quickly spread, evolving into a systemic crisis similar to that of 2008.

The Federal Reserve's "Final Barrier"

The OCC has issued the licenses, but that does not mean everything is settled. For these five newly minted "federal trust banks," the final and most critical barrier to accessing the federal payment system—the right to establish a master account—remains firmly in the hands of the Federal Reserve.

Although the OCC has recognized their banking status, under the U.S. dual banking system, the Federal Reserve retains independent discretion. Previously, Wyoming's crypto bank Custodia Bank initiated a lengthy lawsuit after being denied a master account by the Federal Reserve, and this precedent indicates that there is still a significant gap between obtaining a license and truly accessing Fedwire.

This is also the next main battleground for traditional banking (BPI) lobbying. Since they cannot stop the OCC from issuing licenses, traditional banking forces will inevitably pressure the Federal Reserve to set extremely high thresholds for approving master accounts—such as requiring these institutions to demonstrate their anti-money laundering (AML) capabilities are on par with universal banks like JPMorgan Chase, or demanding additional capital guarantees from their parent companies.

For Ripple and Circle, this game has just entered the second half: if they obtain the license but cannot secure a master account with the Federal Reserve, they will still have to operate through the agency bank model, significantly diminishing the value of the "national bank" label.

Conclusion: The Future Is More Than Just Regulatory Games

It is foreseeable that the future battle surrounding crypto banks will clearly not remain at the licensing level.

On one hand, the attitude of state regulatory agencies remains uncertain. Strong state regulators, represented by the New York State Department of Financial Services (NYDFS), have long played a dominant role in crypto regulation. As federal priorities expand, whether state regulatory authority will be weakened could trigger new legal disputes.

On the other hand, although the GENIUS Act has come into effect, many implementation details still await regulatory agencies to formulate. Specific rules regarding capital requirements, risk isolation, cybersecurity standards, and more will become focal points of policy in the near future. The competition among different stakeholders is likely to unfold around these technical provisions.

Additionally, changes at the market level are also worth noting. As crypto institutions gain banking status, they may become partners of traditional financial institutions or potential acquisition targets. Whether traditional banks acquire crypto institutions to enhance their technological capabilities or crypto companies enter the banking sector in reverse, the financial landscape may undergo structural adjustments as a result.

What is certain is that the OCC's approval is not the end of the controversy but a new starting point. Crypto finance has entered the institutional framework, but how to find a balance between innovation, stability, and competition will remain a question that U.S. financial regulation must address in the coming years.

免责声明：本文章仅代表作者个人观点，不代表本平台的立场和观点。本文章仅供信息分享，不构成对任何人的任何投资建议。用户与作者之间的任何争议，与本平台无关。如网页中刊载的文章或图片涉及侵权，请提供相关的权利证明和身份证明发送邮件到support@aicoin.com，本平台相关工作人员将会进行核查。