The Fintech Log

Ripple Secures Final OCC Trust Bank Charter for Custody; RLUSD Issuance Stays Under New York Oversight

Oct. 28, 2026  •  Article  •  Digital Assets

Summary

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.

Full Article

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.


By 'TFL Editorial Team'
Researched with AI tools. Edited and fact-checked by our editors.



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