The Federal Reserve remains the key to access: how crypto banks are reshaping the American financial infrastructure

On December 12, 2025, the Office of the Comptroller of the Currency (OCC) announced a license that could radically transform the foundations of the U.S. banking system. Five digital asset institutions — Ripple, Circle, Paxos, BitGo, and Fidelity Digital Assets — received conditional approval to convert into federally licensed national trust banks. Contrary to expectations, the market reacted moderately; however, the traditional financial sector immediately grasped the profound significance of this decision.

What appears as a simple licensing grant is actually the first step toward dismantling a system of intermediation that crypto companies have endured for years. For the first time, these entities gain formal recognition as legitimate parts of the federal banking architecture, no longer as tolerated outsiders but as regulated entities.

Beyond the “trust” license, what truly changes in the system

A common source of confusion concerns the exact nature of the approved license. The five crypto institutions did not receive a conventional commercial banking license. Instead, the OCC recognized them as “National Trust Banks” — a well-established banking category in the United States, historically used for asset management and institutional custody.

The intrinsically significant value of this designation lies not in the amount of operations permitted but in the two essential elements: federal regulatory sovereignty and potential access to centralized payment infrastructures.

In the dual banking system of the United States, financial institutions can operate under state or federal supervision. The Federal Reserve does not merely represent a parallel level but exercises a hierarchical preeminence established by the National Bank Act of 1864. An OCC license means the entity is directly regulated by the Department of the Treasury and no longer needs to navigate a patchwork of different requirements across over 50 states.

Before this decision, entities like Circle had to acquire MTL (Money Transmitter License) in each state to operate legally nationwide — a costly, fragmented process inherently risky due to potential disruptions from changing local political priorities. Now, the regulatory framework is unified, removing this administrative complexity.

However, it is crucial to underline what these institutions do not gain: the authority to accept FDIC-insured deposits or to lend credit under the traditional fractional reserve model. Traditional commercial banks have raised specific objections on this point, denouncing an “asymmetric” access to banking privileges.

For stablecoin companies, this limitation is strategically consistent with their operational architecture. Issuers like Circle (USDC) and Ripple (RLUSD) operate on 100% reserve models, which do not generate risks of “maturity mismatch” typical of traditional banking credit. FDIC insurance would be superfluous and would increase compliance burdens without actual benefits.

Even more significant: the trust bank license creates legally binding fiduciary duties. The holder institutions must strictly segregate customer assets from their own funds and prioritize customer interests — a federal obligation, not just a corporate promise. After the FTX scandal, this shift represents a structural safeguard of utmost importance for the entire ecosystem.

The real prize: transitioning from intermediary to payment node

The core of this transformation lies in what crypto institutions can now pursue: opening primary accounts at the Federal Reserve and direct access to Fedwire and other federal settlement networks.

For decades, the crypto sector has operated as an external user of the dollar payment system. Every final settlement had to go through intermediary commercial banks — Circle to issue USDC, Ripple to provide on-demand cross-border payments, all depended on this chain of intermediation. This “correspondent banking” model has created three persistent vulnerabilities:

First: survival uncertainty. In 2023, the crypto sector experienced a wave of systematic de-bancarization. When correspondent banks withdrew their services, the fiat channels of crypto companies were almost immediately interrupted, blocking critical operations. This risk remains as long as intermediation is necessary.

Second: inefficient cost structure. Every transfer through banking intermediaries accumulates fees on top of fees and involves settlement delays of at least T+1 or T+2. For high-frequency, mission-critical operations like stablecoin settlement, this latency is inherently a significant structural limitation.

Third: exposure to banking credit risk. When Silicon Valley Bank collapsed in March 2023, Circle had about $3.3 billion in USDC reserves temporarily blocked in an intermediary bank. This event remains emblematic of the counterparty risks inherent in the intermediation model.

The status of federal trust bank reconfigures this dynamic entirely. Once the OCC and subsequently the Federal Reserve approve the opening of primary accounts, Ripple and Circle will be able to connect directly to Fedwire for real-time final settlements with irrevocability guaranteed. This means the crucial node of fund settlement positions them, for the first time, at the same systemic level as JPMorgan or Citibank.

The algebra of savings: from marginal to structural transformation

Eliminating banking intermediation generates not just marginal savings but transformative ones. The principle is straightforward: without intermediaries, there are no intermediation fees, liquidity surcharges, or account maintenance costs.

Based on the Federal Reserve’s public fee structure for 2026 and established industry practices, direct settlements via Fedwire cost significantly less than commercial wire transfers for high-value, high-frequency transactions. For Circle — with USDC reserves exceeding $80 billion — daily fund traffic is astronomical. Annual savings on transaction fees alone could reach hundreds of millions of dollars.

This is not marginal optimization but a fundamental reconfiguration of profitability across the entire value chain.

Stablecoins gain a renaissance credit status

In the previous model, USDC and RLUSD represented “digital vouchers issued by tech companies” — their solidity depended on corporate governance and the strength of the custodian banks.

In the new regulatory framework, the collateral reserves of stablecoins will be held within a federally supervised trust system overseen by the OCC and legally segregated from the issuer’s proprietary assets. It is not a CBDC nor FDIC insurance, but the combination of “100% collateral + OCC federal supervision + legally binding fiduciary duties” confers a regulatory credibility surpassing almost all offshore stablecoins.

The most visible operational impact concerns cross-border payments. Ripple’s On-Demand Liquidity (ODL) product has long been constrained by banking hours and the availability of fiat channels. Once integrated into the federal settlement system, fiat-to-onchain conversion will no longer be limited by predefined windows, drastically improving the fluidity of international settlements.

The counteroffensive of traditional banks and the final obstacle

For the crypto sector, this marks a milestone awaited for years; for Wall Street, it is a redistribution of territory that triggers coordinated defensive reactions. The Bank Policy Institute (BPI) — representing JPMorgan, Bank of America, and Citibank — has raised three categories of objections.

The first concerns superficial regulatory arbitrage. BPI claims that crypto companies use the “trust” license to mask core banking activities (payments, systemically important regulations), but keep parent companies (Circle Internet Financial, Ripple Labs) outside consolidated Federal Reserve supervision. This creates regulatory gray zones where software bugs or investment decisions by the parent could generate unmonitored risk exposures.

The second concerns the violation of the firewall between banking and commerce. Traditional banks fear that tech companies owning banks could use access to federal payment systems for asymmetric competitive advantages, without respecting obligations like the Community Reinvestment Act (CRA).

The third concerns systemic risk without a safety cushion. Since these new trust banks do not benefit from FDIC coverage, a panic related to stablecoin de-pegging would lack an insurance buffer. BPI warns this could trigger systemic liquidity crises similar to 2008.

However, the real obstacle remains: the Federal Reserve. The OCC has granted the license, but opening primary accounts at the Fed remains entirely at the Fed’s discretion. Previously, the Wyoming crypto bank Custodia filed a lengthy lawsuit after the Fed refused to open an account, demonstrating that a wide gap still exists between banking license and actual Fedwire access.

This will be the next battleground. Traditional banks will likely exert pressure for the Federal Reserve to impose AML (anti-money laundering) standards equivalent to JPMorgan, require additional capital guarantees from parent companies, or impose unusually strict governance requirements. Without this access gate, the value of the license remains partially neutralized.

From exception to infrastructure: the new balance of digital finance

The OCC approval marks the first chapter, not the conclusion. The battle over crypto banks will continue on multiple fronts: the evolution of state supervision (the New York State Department of Financial Services might contest its authority); implementation of details from the GENIUS Act signed by Trump in July 2025; future market adjustments (potential cross-acquisitions between traditional banks and crypto entities to consolidate technological capabilities).

What is certain is that the crypto sector has definitively transitioned from being an external user of the banking system to a building block of the federal financial infrastructure. This does not eliminate regulatory controversies but shifts them from questions of legitimacy to issues of technical calibration: how to balance innovation, stability, and competition will remain the central challenge of American finance in the coming years.