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Exploring the implications of the first major crypto legislation for financial institutions in the US
On July 18, 2025, the President of the United States signed the Guiding and Establishing National Innovations for U.S. Stablecoins Act known as the GENIUS Act which established the first comprehensive federal regulatory framework for payment stablecoins. It aims to promote innovation, ensure 1:1, U.S. dollar-backed reserves, and authorize both bank and nonbank entities to issue stablecoins under strict supervision.
The GENIUS Act names the Office of the Comptroller of the Currency (OCC) as a primary supervisor for permitted payment stablecoin issuers (PPSIs). The OCC is responsible for licensing, and regulating, and supervising nonbank issuers, national bank subsidiaries, and foreign entities. The OCC is in the process of building out the requirements for these institutions.
A national trust bank charter is a specialized federal business license issued by the OCC, authorizing institutions to operate nationally as fiduciaries and provide services like custodial, safekeeping, and settlement. These entities are generally restricted from taking demand deposits or making traditional loans, and are not required to be insured by the FDIC, though they must abide by National Bank Act. This makes it a great fit for crypto firms seeking to provide custody and asset management services.
In summary, a charter includes:
|
Feature |
Description |
|---|---|
|
Federal Authority |
Allows operations across all US states under a single federal supervisor (the OCC), bypassing the complex and expensive state-by-state licensing process. |
|
Permissible activities |
Focused on fiduciary services such as digital asset custody, clearing, settlement, and staking. |
|
Key restrictions |
These banks cannot take FDIC-insured deposits or engage in general commercial lending, separating their activities from traditional banking. |
|
Regulatory standing |
Provides a "gold standard" of federal oversight, significantly increasing credibility with institutional investors and partners. |
Prior to the GENIUS Act, there were 60 national trust banks, and since the signing of the Act, nearly 30 de novo applications have been filed (thru the end of February 2026).
On March 2, 2026, the OCC posted a proposed rulemaking to implement the GENIUS Act. The notice generally sets forth the regulations that would apply to permitted payment stablecoin issuers and foreign payment stablecoin issuers under the OCC’s jurisdiction as well as certain custody activities conducted by OCC-supervised entities. The proposed rule addresses all of the regulations the OCC is required to promulgate under the GENIUS Act other than those related to the Bank Secrecy Act, Anti-Money Laundering, and Office of Foreign Asset Control sanctions, which will be addressed in a separate rulemaking in coordination with the Department of Treasury. The OCC will continue to coordinate with other agencies responsible for implementing aspects of the GENIUS Act.
The majority of the GENIUS Act OCC rules will be addressed in a new 12 CFR 15, which will include standards and requirements related to the following:
The rule will revise the capital adequacy standards in 12 CFR 3, prompt corrective action regulations in 12 CFR 6, assessment of fees in 12 CFR 8, and rules of practice and procedure in 12 CFR 19.
The OCC has granted conditional approvals to a growing list of firms, including Bridge (Stripe), Paxos, and Ripple. Once conditional approval is granted, the bank has one year to stand up the bank which includes passing a full examination. Several banks have passed all requirements and have opened their doors business including Erebor and Fidelity.
The opportunity goes beyond crypto firms such as:
Transitioning to a federally regulated model presents significant operational challenges.
The creation of the infrastructure is complex, and it must not impact your compliance with the rules and regulations. At Regnology, we serve both the regulated and the regulators. Our solutions are built to solve these exact challenges.
We provide a single, unified platform that automates the entire regulatory lifecycle, from data aggregation to final report submission. We offer Risk, Finance, and Reporting solutions that includes capital, liquidity, general and sub-ledgers, consolidation, and various federal reporting requirement.
Ready to learn more? Contact a Regnology expert today, and let's discuss your path to becoming a federally compliant financial institution.
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