The American Bankers Association (ABA) is urging the Office of the Comptroller of the Currency (OCC) to slow its approval of national trust bank charters for crypto and stablecoin firms until the regulatory landscape under the Guiding and Establishing National Innovation for US Stablecoins (GENIUS) Act is clearer. 

In a Wednesday comment letter on the OCC’s national bank chartering notice of proposed rulemaking, the trade group warned that recent and future applicants engaged in stablecoin and digital asset activities face still‑unsettled oversight from multiple federal and state regulators. 

The ABA said that the OCC should not advance applications where an institution’s full regulatory obligations, including under forthcoming GENIUS Act rulemakings, are not yet fully defined.

​The association warned that uninsured, digital asset‑focused national trusts raise unresolved safety and soundness, operational and resolution issues, particularly around the segregation of customer assets, conflicts of interest and cybersecurity. 

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It also cautioned that national trust charters could be used to avoid registration and scrutiny by the Securities and Exchange Commission (SEC) or Commodity Futures Trading Commission (CFTC) when firms engage in activities that would otherwise trigger securities or derivatives regulation. 

The ABA urged the OCC to be “patient,” resist applying traditional timing expectations to these applications, and ensure each charter applicant’s regulatory responsibilities “come fully into view” before moving applications forward. 

​The association further called for greater transparency around how the OCC calibrates capital, operational and resilience standards in conditional approvals for crypto‑related charters, and pressed the agency to tighten naming rules so that limited‑purpose trust banks that are not engaged in the business of banking cannot use “bank” in their names. 

That, it argued, would reduce the risk of consumer confusion about the status and safety of obligations at uninsured entities.

Related: Stablecoin rewards provisions face industry test in Senate crypto bill

​Warning after new crypto trust charters

The intervention comes less than two months after the OCC granted conditional national trust bank approvals to five crypto firms: Bitgo Bank & Trust, Fidelity Digital Assets, Ripple National Trust Bank, First National Digital Currency Bank, and Paxos Trust Company.

On Dec. 12, 2025, the OCC greenlighted a path for these companies to hold and manage customer digital assets under a federal charter while remaining outside the deposit-taking and lending business. 

The same banking lobby is also pressing Congress, through pending crypto market structure legislation such as the Digital Asset Market Clarity (CLARITY) Act, to curb stablecoin rewards, contending that yield‑bearing stablecoins and affiliate “rewards” programs would function as bank‑like products without being subject to the full bank regulatory regime.

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