The Fintech Log
# Banking Regulation

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.

Oct. 29, 2026 • 3 min read

Modern Treasury applied to the Office of the Comptroller of the Currency on October 5, 2026, to establish a limited-purpose national trust bank focused on stablecoin custody and settlement. The proposed institution would connect stablecoin and fiat transactions with the company’s existing payment infrastructure under direct federal supervision. Its software and payment services would remain separate. The bank would safeguard client assets and facilitate settlement, but would not make commercial loans, accept retail demand deposits or issue a stablecoin. The application follows Modern Treasury’s 2025 acquisition of Beam, which expanded its stablecoin payment capabilities. A national trust charter could provide a single federal framework for authorized custody and fiduciary services. The filing is in the OCC’s initial review and public comment stage. The bank cannot open without final authorization and satisfaction of pre-opening requirements. Modern Treasury’s bid comes amid growing scrutiny of digital-asset trust charters, with traditional banking groups raising concerns about FDIC coverage and banking safeguards.

Oct. 5, 2026 • 3 min read