Ripple Secures Final OCC Trust Bank Charter for Custody; RLUSD Issuance Stays Under New York Oversight
Oct. 28, 2026 • Article • Digital Assets
Ripple received final approval on 26 October 2026 for Ripple National Trust Bank, giving it a federally chartered institution for fiduciary and custody activities. The charter does not authorize commercial deposits or loans, and it does not transfer issuance of Ripple’s RLUSD stablecoin to the new bank.
RLUSD issuance remains with Standard Custody & Trust Company under New York State Department of Financial Services supervision. BNY is the primary custodian of the dollar deposits and U.S. Treasury reserves backing the stablecoin. The arrangement separates a federal custody role from state-supervised issuance. It also comes as the OCC implements the GENIUS Act’s stablecoin rules and faces a lawsuit from the Independent Community Bankers of America challenging its authority to grant national trust charters to crypto firms. Ripple has separately announced an expanded partnership with BNY and Robinhood focused on institutional custody capabilities and exploring tokenized trade finance.
Ripple received final approval from the Office of the Comptroller of the Currency (OCC) on 26 October 2026 for Ripple National Trust Bank, establishing a federally chartered institution for fiduciary and custody activities. The approval gives Ripple a federal trust-bank role, but it does not move issuance of its RLUSD stablecoin into that bank.
RLUSD will continue to be issued by Standard Custody & Trust Company under the supervision of the New York State Department of Financial Services (NYDFS). That division is central to the charter’s significance: Ripple now has a federal institution for specified trust activities alongside a state-supervised stablecoin issuer, rather than a single institution handling both functions.
What the charter permits
Ripple National Trust Bank, headquartered in New York, holds charter number 25364. Its national trust charter was issued pursuant to Section 92a of the National Bank Act and limits the bank to fiduciary and custody functions. It cannot take commercial deposits or make commercial loans. The approval should therefore not be read as authorization for Ripple to operate a conventional deposit-taking bank.
Assets held by Ripple National Trust Bank as collateral trustee are segregated off its balance sheet and are not insured by the Federal Deposit Insurance Corporation. That distinction matters when assessing what the federal charter provides: it establishes a regulated role for holding assets in a trust capacity, but it does not turn those assets into FDIC-insured bank deposits.
Ripple applied for the charter in July 2025 and received conditional OCC approval in December 2025 before the final approval in October 2026. Circle had already become the first digital asset issuer to receive final OCC national trust bank approval under the post-GENIUS framework, obtaining its charter in July 2026. Ripple’s approval is thus part of a broader use of the trust-bank route by digital asset businesses, not the first such decision.
How RLUSD fits into the federal-state model
The trust bank’s federal status does not change the identified issuer or state supervisor of RLUSD. Standard Custody & Trust Company remains responsible for issuance under NYDFS supervision. BNY serves as the primary custodian for the dollar deposits and U.S. Treasury reserves backing approximately $2.5 billion in circulating RLUSD. Reported circulation figures differ across sources, so that amount is best treated as an approximation rather than a precise current balance.
The GENIUS Act, enacted in July 2025, supplies a separate statutory framework for payment stablecoins. It gives holders super-priority over general creditors with respect to segregated reserve pools if an issuer is liquidated or becomes insolvent. The act also excludes payment stablecoins from the definitions of securities and commodities, while issuers do not gain direct access to Federal Reserve master accounts.
On 21 October 2026, the OCC issued its final rule implementing the GENIUS Act, with an effective date of 18 January 2027. The rule establishes a 5% minimum daily liquidity requirement for reserves and requires redemption processing within two business days. These requirements form part of the regulatory context for stablecoins, but they do not erase the distinction between Ripple’s federally chartered trust bank and its state-supervised RLUSD issuer.
Expansion plans and a legal challenge
The day after the charter approval, Ripple announced an expanded partnership with BNY and Robinhood to broaden institutional custody capabilities and explore tokenized trade finance on the XRP Ledger. Those plans point to potential uses for its custody infrastructure; the announcement does not establish that tokenized trade finance services have launched.
The OCC’s approach also faces a challenge. In October 2026, the Independent Community Bankers of America filed a federal lawsuit against the regulator, alleging it exceeded its statutory authority by granting national trust charters to crypto firms without subjecting them to standard depository banking scrutiny. That is the banking group’s claim, not a finding by a court.
For Ripple, the immediate regulatory picture is consequently divided rather than consolidated. Its new bank has a defined federal custody and fiduciary mandate; RLUSD issuance remains under New York supervision; and the OCC’s implementation rules and chartering authority are subject to separate regulatory and legal developments. The charter expands Ripple’s institutional structure without making its trust bank a commercial lender, deposit-taking bank or replacement RLUSD issuer.
Mastercard and Visa are extending stablecoin technology into the systems that settle card payments between financial institutions, while leaving the consumer checkout experience largely unchanged. Mastercard completed its acquisition of stablecoin infrastructure provider BVNK in August 2026 and has expanded its network’s settlement options to include regulated stablecoins. Visa, meanwhile, is working with Stripe-owned Bridge and Lead Bank on on-chain settlement for card programs. The shift became more concrete in September, when SoFi Bank moved its credit and debit card issuing portfolio to live settlement using its bank-issued SoFiUSD. That portfolio represents more than $25 billion in annualized card volume, a measure distinct from the value settled in stablecoins. Visa separately reported an annualized stablecoin settlement run rate exceeding $25 billion in October. The networks’ initiatives target the back-end movement and reconciliation of funds, including periods when traditional bank settlement rails are unavailable; they do not require merchants to accept cryptocurrency.
The European Central Bank has launched Pontes, a bridge connecting tokenised-asset platforms to the Eurosystem’s TARGET Services for wholesale settlement in central bank money. The arrangement enables atomic delivery-versus-payment settlement, in which an asset and its payment move together. It does not yet make wholesale settlement available around the clock: Pontes depends on T2 operating hours and requires tokenised central bank money balances to be defunded at the end of the day. ECB Executive Board member Piero Cipollone says the Eurosystem plans to extend Pontes operating hours substantially by mid-2027 and reach 24/7/365 availability in 2028. Separately, the Bank for International Settlements’ Project Agorá has tested cross-border payments using a shared programmable ledger that brings tokenised commercial bank deposits and central bank reserves into a single settlement process. Both initiatives address delays and liquidity demands in wholesale payments, but neither makes continuous, cross-border settlement available today.
Project Agorá’s real-value testing settled 30 live, multi-currency transactions worth approximately CHF 800,000, with atomic settlement averaging about 80 seconds. The tests involved 28 commercial institutions and five central banks. The result shows how tokenised commercial bank deposits and central bank reserves could support faster cross-border settlement, though it does not establish that settlement latency has been eliminated. The project’s prototype found that tokenisation did not change the legal character or regulatory obligations of deposits and reserves. Its design also let participating institutions conduct compliance checks concurrently. Seven more commercial banks joined in September 2026, taking private-sector participation to nearly 50 institutions. At Sibos in October, banking executives described the testing pipeline as a step towards production trials alongside the European Central Bank’s Pontes platform. The Federal Reserve Bank of New York did not participate in the live test transactions, an important qualification for the US dollar tests.
Ripple’s final federal trust bank charter, a Moody’s investment-grade rating for RLUSD and a planned expansion of the stablecoin’s availability on Coinbase have strengthened its position as a regulated digital dollar. Coinbase said Global Exchange access, including eligibility to use RLUSD as trading collateral, will follow its initial retail and prime rollout. Moody’s assigned RLUSD an A2 long-term deposit rating and a P-1 short-term rating, the first investment-grade rating it has given a stablecoin. The distinctions behind those developments matter. Ripple National Trust Bank manages RLUSD’s reserve collateral, but the legal issuer remains Standard Custody & Trust Company, a New York-regulated Ripple subsidiary. The national trust bank is uninsured and cannot take commercial retail deposits or extend credit. Moody’s also noted that holders do not currently own the underlying reserves directly and that statutory bankruptcy protections depend on implementation of the GENIUS Act, whose rules take effect in January 2027.
Ramp partnered with Stripe and Bridge in July 2026 to deploy stablecoin rails for business bill payments and yield-bearing stablecoin accounts funded through standard fiat bank accounts. The arrangement shows how stablecoins can be incorporated into familiar payment workflows without requiring businesses to fund every transaction with digital assets. The economics depend on more than the cost of moving a token on-chain. Stripe charges merchants 1.5% for stablecoin checkout transactions, versus its standard card-processing fee of 2.9% plus $0.30; neither figure establishes the price of Ramp’s bill-payment service. Businesses receiving fiat may also face foreign-exchange and off-ramp costs, typically 0.3% to 2.0% when converting into local banking systems. Domestic clearing networks and compliance checks remain part of end-to-end delivery. Bridge’s issuance and transfer tools, alongside its conditional U.S. trust-bank approval, illustrate the infrastructure behind those payments—but not the elimination of every payment cost.
StraitsX has opened onboarding for digital payment token providers across more than 100 markets through an expanded card-issuing architecture developed with Visa. Integration documentation published on 26 October 2026 describes a multi-BIN model that combines issuing sponsorship, transaction authorization, compliance screening and fiat clearing. The approach lets participating providers build stablecoin-backed card products while merchants continue to receive conventional fiat payments through Visa’s network. StraitsX says its card gross transaction value rose 40-fold year on year from Q4 2024 to Q4 2025, while cards issued across Asia increased 83-fold. On-chain issuer telemetry recorded monthly card transaction volume of $310 million to $438 million through October 2026. The company’s stated $6 billion annualized card transaction figure is distinct from its cumulative $70 billion in processed stablecoin volume. StraitsX and Visa have also scheduled demonstrations of agentic payments for November 2026.



