Crypto and the fight over the word “bank”

On October 2, 2026, America’s community-bank lobby sued the regulator of national banks. The Independent Community Bankers of America, or ICBA, is challenging the route through which cryptocurrency businesses obtain national trust bank charters. At stake is a commercially valuable label. Being a federally chartered bank can help a company establish credibility with institutional clients and identify a national supervisor. The financial protections customers may associate with that label come from a much more specific combination of authorisations, laws and contracts. ^{1, 2, 3}

The association accuses the Office of the Comptroller of the Currency, the OCC, of exceeding the authority Congress gave it. The agency maintains that it is applying longstanding law to evolving services. For customers, the dispute leads to a practical question: who owes them what, and which protection becomes available when an intermediary fails? ^{2, 4}

Reading the actual approvals produces a more complicated picture than an unregulated crypto industry moving into banking. Capital and liquidity conditions exist. So do substantial differences from insured deposit-taking institutions. Meanwhile, the community bankers demanding stronger safeguards are defending their own fees, customer relationships and an important source of funding: customer deposits. ^{2, 13, 18}

The federal label

The OCC charters and supervises national banks. A national trust bank is a specialised institution whose authorised business centres on holding, administering or managing assets for others. Here, “trust” refers to a category of activities and legal duties. It is considerably more specific than a regulator’s endorsement of a company’s reliability. ^{5, 6, 8}

A deposit-taking bank records a liability when a customer places money with it. The customer has a claim against the bank, which holds assets on its own balance sheet, including loans. A custodian instead arranges to safeguard assets entrusted to it and return them to their owners. Asset segregation, ownership rights and the custodian’s responsibilities become central. A digital interface can describe either relationship as an account, even though the consequences in insolvency can be very different. ^{6, 18, 30}

American law has long accommodated national banks with limited operations. Specialisation can serve a legitimate economic purpose: supervising a particular financial business without requiring it to become a full-service bank. The dispute concerns how far that specialised perimeter extends and which businesses qualify. ICBA argues that the OCC now uses the trust charter for activities too far removed from its fiduciary foundations. ^{2, 5, 7}

For an applicant, federal status may also simplify conversations with counterparties looking for a clear supervisory framework. ICBA explicitly objects to the credibility this provides. But the agencies involved perform separate jobs. The OCC authorises and supervises activities; the Federal Deposit Insurance Corporation protects qualifying deposits; Federal Reserve Banks decide requests for access to their accounts and payment services. An OCC charter does not guarantee product insurance or access to Federal Reserve accounts and services. ^{1, 18, 23}

The legal hinge

The contested amendment is short. The OCC replaced references to “fiduciary activities” in its chartering regulation with “operations of a trust company and activities related thereto.” It announced the final rule on February 27, 2026. Publication in the Federal Register followed on March 2, with an effective date of April 1. Announcement, publication and legal commencement are separate events. ^{4, 5}

Acting as a fiduciary entails duties towards a beneficiary, including care and loyalty. Technical custody carried out on a customer’s instructions in a non-fiduciary capacity has a different legal basis. It still carries contractual and regulatory obligations, but those obligations do not automatically amount to the full fiduciary regime. What the institution actually does, the discretion it exercises and the applicable law determine the distinction. ^{6, 8}

The OCC relies on a sentence Congress added to the National Bank Act in 1978. It confirms the validity of national banks whose operations are limited to those of a trust company and related activities. In the agency’s reading, trust-company operations have historically included both fiduciary services and some non-fiduciary custody and safekeeping. The nature of the service matters more to this reasoning than the technology used to record an asset. ^{5, 6, 7}

ICBA reads the same sentence alongside the fiduciary powers provided under section 92a. It argues that Congress protected specialised fiduciary institutions, rather than giving the OCC a general licence to create banks that neither take deposits nor operate primarily as fiduciaries. The complaint also invokes administrative-law requirements for reasoned decision-making and the need for clear congressional authorisation for a major economic change. These are the claimant’s arguments, awaiting judicial determination. ^{2, 7, 8}

One consequential issue remains unresolved by the rule: how much fiduciary business a national trust bank must perform. In the explanatory preamble, the OCC treats that question, along with several broader policy objections, as outside the scope of this amendment. Individual application reviews therefore retain considerable importance. The argument concerns both the statutory boundary and the discretion exercised within it. ⁵

An established doctrine gains momentum

The broader interpretation already appeared in Interpretive Letter 1176, dated January 11, 2021. Its author, Jonathan V. Gould, was then the OCC’s chief counsel. He became Comptroller of the Currency on July 15, 2025. There is a documented continuity: the official now responsible for defending this interpretation helped formulate it five years earlier. That identifies the doctrine’s institutional origin; it does not, by itself, establish preferential treatment of an applicant. ^{6, 9}

Supervisory policy has changed direction. In March 2025, the OCC removed a preliminary non-objection process for certain crypto activities that had been introduced in its November 2021 Interpretive Letter 1179. It also withdrew from two 2023 interagency statements on crypto-related risks. In May 2025, the agency clarified banks’ ability to execute transactions for custody customers and use third parties subject to appropriate risk management. Established banks, as well as prospective entrants, benefit from this opening. ^{10, 11}

The OCC’s historical argument has an empirical foundation. As of September 30, 2025, the uninsured national trust banks it supervised reported $6.8 trillion in assets under administration. Of that total, $5.2 trillion was in fiduciary accounts and $1.6 trillion in custody and safekeeping accounts. The figures appear in the OCC’s charter decisions, including its Paxos approval. ¹⁵

Custody therefore already exists on a substantial scale within this institutional category. The numbers describe neither the banks’ deposits nor their own balance-sheet assets. They also cover more than crypto. They illustrate the diversity of an established business model, rather than settle whether every proposed new activity, or any possible mixture of activities, falls within its legal scope. ^{5, 15}

Protego puts the claims to a test

The individual approval challenged in the suit makes the argument tangible. On February 13, 2026, the OCC gave preliminary conditional approval to National Digital Trust Company, a proposed subsidiary of Protego Holdings. Corporate Decision 1366 describes crypto custody, a trading platform, a platform matching lending and borrowing customers, and technical issuance services for clients. Under the last business line, the client would issue the token. ¹³

Matching two customers who wish to lend and borrow assets is different from originating a loan on the bank’s own balance sheet. Certain staking, governance and treasury-management services can also be provided in a fiduciary capacity. Neither a miniature conventional lender nor a basic digital vault adequately describes the combination of functions in the proposed business. ¹³

The approval sets explicit financial conditions. The bank must maintain at least $15 million in Tier 1 capital, a regulatory measure of its own funds. The associated eligible liquid asset requirement is the greater of half that capital or $7.5 million. A further pool of eligible liquid assets must cover 180 days of operating expenses in a wind-down scenario. The same liquid assets cannot count towards both requirements. These conditions apply during the first three years of operation. Eligible liquid assets must be unencumbered, exceed repayment liabilities and exclude affiliate obligations; qualifying insured deposits and US government securities mature within 90 days. ¹³

Capital absorbs losses; liquidity meets payments. Adding $15 million to $7.5 million and announcing a $22.5 million cushion would confuse those dimensions. At the capital floor, the $7.5 million requirement concerns the liquid composition of the resources specified in the approval. Liquidity covering 180 days of wind-down expenses must be held separately from that first liquid-asset requirement. The letter does not publish its dollar amount. ¹³

Whether the conditions are sufficient depends on the business eventually launched: its volumes, technical dependencies, operational exposures and ability to return client assets. Public documents do not support reconstructing a complete failure scenario. They do establish that this applicant received no blanket exemption from capital or liquidity requirements. ¹³

The published complaint also contains a documentary inconsistency worth resolving. Paragraph 14 identifies Protego’s earlier February 4, 2021 conditional approval, number 1259. The narrative and ICBA’s announcement target the February 2026 decision, numbered 1366, for National Digital Trust Company. The two public decisions are distinct. This discrepancy warrants clarification; the reviewed material does not establish a procedural consequence. ^{1, 2, 13, 14}

Approval is a sequence

Conditional approval is a stage in establishing a bank. Requirements must still be fulfilled, followed by a pre-opening examination. Protego’s letter expressly reserves final authorisation to commence business. The regulator can modify, suspend or rescind its preliminary decision. A headline announcing a licence can therefore get several steps ahead of an institution’s actual opening. ¹³

On December 12, 2025, the OCC announced five conditional approvals: new banks for Circle and Ripple, and conversions of existing institutions for BitGo, Fidelity and Paxos. That announcement captures their status on a particular date. It neither makes all five operational in December nor leaves them permanently classified as awaiting final approval. ¹²

On July 10, 2026, Circle announced final approval for First National Digital Currency Bank, operating as Circle National Trust. Its disclosure describes an initial business providing fiduciary digital-asset custody for Circle and its affiliates. Direct services to a limited number of institutional customers are contemplated later, depending on demand. Management of USDC reserves is described as a future capability. ¹⁶

The OCC’s list of active trust banks as of August 31, 2026 includes BitGo, Fidelity Digital Assets, Paxos and Circle’s First National Digital Currency Bank. This official snapshot establishes their status on that date. ³²

That distinction matters. A custody subsidiary’s charter does not automatically extend identical banking protection across every group entity, product and token holder. The initially authorised service should be distinguished from the broader business plan. Describing an infrastructure project in sweeping terms can imply coverage well beyond its opening scope. ^{16, 18}

What customers can actually claim

A qualifying deposit at an insured bank benefits from FDIC protection under the applicable rules. The standard maximum is $250,000 per depositor, per insured bank, for each account ownership category. Opening several accounts in the same category at the same institution does not freely multiply coverage. Crypto investments are excluded, even when offered through an insured bank. ¹⁸

Custodied assets depend on another set of safeguards: segregation, accurate records, secure control of access and keys, enforceable duties and restitution rights. Market losses remain an asset owner’s exposure. Losses caused by an intermediary’s failure raise separate questions of liability and recovery. A federal supervisor’s name does not promise to reimburse the market value of a portfolio. ^{6, 18, 30}

The receivership rules expressly separate assets held in a fiduciary or custodial capacity, as identified in the bank’s records, from its general assets. Those client assets cannot fund unrelated creditor claims. This is a meaningful legal protection. Its effectiveness depends on the assets existing, the rights being properly established and usable records identifying them. It protects the return of property; deposit insurance addresses a different kind of claim. ^{29, 30}

Misunderstanding deposit protection is a real enforcement concern. In August 2023, the FDIC issued a cease-and-desist letter to Unbanked over misleading representations about deposit insurance. That is a separate case. It illustrates the need to examine what companies tell customers, without attributing the same behaviour to the businesses involved in the 2025 and 2026 charter decisions. ²⁸

ICBA also challenges the arrangements for the failure of an uninsured national bank. A legal framework exists: the OCC’s receivership rules are codified in Part 51. The practical question is how it would handle a complex crypto institution. Recovering records, restoring technical access, maintaining essential service providers and returning assets would all matter. The existence of a resolution procedure and its operational resilience require separate assessments. ^{2, 13, 30}

Stablecoins introduce another claim

A payment stablecoin is designed around redemption for a fixed monetary value, such as one dollar, backed by reserves. Holding the token connects the customer to an issuer and to the applicable redemption terms. Keeping reserves at an insured bank or investing them in Treasury securities does not turn each token into the holder’s own insured deposit or a direct obligation of the United States. ^{18, 20}

The GENIUS Act, enacted on July 18, 2025, establishes a dedicated framework for payment stablecoins. It requires identifiable backing reserves at least equal to outstanding issuance and specifies eligible reserve assets. It expressly recognises uninsured national banks as one possible category of issuer, subject to separate approval to issue stablecoins. It also states that payment stablecoins lack federal guarantees and deposit insurance, and prohibits representations to the contrary. ²⁰

Section 20 provides for commencement on the earlier of two dates: eighteen months after enactment on July 18, 2025, which is January 18, 2027, or 120 days after the final regulations issued by the primary federal regulators specified in that section. In its September 30 procedural rule, Treasury identifies January 18, 2027 as the expected date. The OCC issued its main proposal in February and an anti-money-laundering and sanctions proposal on June 22. On August 19, Jonathan Gould said a final rule would be issued by November. That announced target does not establish that the framework is already operational. ^{20, 21, 22, 33, 34}

Treasury’s rule, effective September 30, sets out the procedure for certifying state regimes. Certifications will be accepted only after approval of the information collection under the Paperwork Reduction Act and a Treasury notification. That procedure does not, by itself, trigger section 20’s 120-day period. ^{20, 22}

The OCC draws support from Congress’s express recognition of uninsured national-bank issuers in GENIUS. ICBA responds that a statute regulating stablecoin issuance does not settle the legality of every other crypto service authorised through a trust charter. The new legislation supplies arguments to both sides, depending on the particular provision and activity under consideration. ^{2, 15, 20}

Direct access to Federal Reserve payments is another issue again. In a May 20, 2026 proposal, the Board outlined a specialised payment account with limited services, no intraday credit or discount-window access, and no interest on balances. It reaffirmed that Reserve Banks decide access requests and that legal eligibility would remain unchanged. This is a proposal for a particular service, rather than an entitlement attached to every OCC charter. ²³

An individual access decision has already been made. On March 4, 2026, the Kansas City Fed approved a limited account for Payward Financial, known as Kraken Financial, for an initial one-year term. The institution holds Wyoming’s specialised SPDI status. This decision is separate from the Payward National Trust Company OCC application mentioned above. ^{17, 35}

The central bank is divided on the safeguards. Governor Michael Barr’s dissent argues that the proposal lacks sufficiently specific protections against money laundering and terrorist financing for some institutions the Fed does not supervise. The debate over payment innovation therefore includes disagreements within the authorities, as well as the public confrontation between incumbent banks and crypto businesses. ²⁴

Following a deposit through the system

The community banks’ financial interest becomes clear when the money is followed. Consider a customer transferring $100, an illustrative amount rather than an observed transaction, from Bank A to a stablecoin issuer’s account at Bank B. The issuer gives the customer 100 dollar-denominated tokens. Bank A loses a deposit, while Bank B receives one in the issuer’s name. In this simplified first step, total system deposits are unchanged. Their location and ownership have shifted. ²⁵

Now suppose the issuer uses the $100 to buy an outstanding Treasury bill from a nonbank investor whose account is at Bank C. Once the transaction settles, the seller has a $100 deposit at C, while the issuer holds the bill as a reserve asset. In this specifically defined example, deposits have again moved rather than disappeared. Purchasing newly issued government debt, buying from a bank or choosing other reserve investments would produce different accounting entries. ²⁵

Bank A’s problem nevertheless remains. It has lost a customer deposit and needs to adjust its funding. It may attract replacement deposits, pay more for them, obtain market financing or change its balance sheet. The outcome depends on access to funding, liquidity, capital and demand for credit. There is no universal coefficient turning each dollar converted into a stablecoin into a dollar of cancelled loans. ²⁵

Concentration can change the character of funding even for banks receiving the money. Numerous relatively stable retail accounts may be replaced by large balances belonging to a small number of issuers, exposed to sudden redemption requests. A bank holding more liquidity against those flows has less room, at a given balance-sheet size, for other exposures. ^{25, 26}

A February 2026 Federal Reserve Bank of New York paper by Michael Junho Lee and Donny Tou investigates this channel. The analysis covers one issuer’s transactions from September 2021 to January 2025 and three main partner banks after the March 2023 banking shock. Linking interbank payments to blockchain activity, the authors find greater liquidity demands and reserve holdings among issuer-partner banks, alongside a reduction in the loan share of assets relative to peers. Their sample does not identify a reduction in lending across the entire American banking system. ^{26, 27}

The result nevertheless adds an important dimension. A bank can attract stablecoin-related deposits while finding them more demanding to service and finance. Conversely, foreign demand for digital dollars may bring additional funds into the US system. Market scale, the origin of users and the allocation of issuer reserves determine the eventual effect. ^{25, 26}

Competition needs a legible boundary

ICBA raises a legitimate question: should intermediaries offering comparable services face different obligations simply because of their legal form? Its commercial interest is equally explicit in the complaint. The association says customer migration could deprive its members of asset-management income and deposits. Consumer protection and defence of a banking franchise sit within the same lawsuit. ²

The differences extend beyond individual products. The Community Reinvestment Act assesses how certain insured depository institutions meet local credit needs, including those of low- and moderate-income neighbourhoods. The uninsured trust banks considered here fall outside that framework. ICBA sees an asymmetry: local banks carry community obligations while competitors can attract some of the same customers. The OCC’s answer is that the statute’s coverage depends on the institution’s legal status. ^{1, 15, 31}

The boundary also matters for parent groups. The first condition in Protego’s approval requires the bank to stay outside the Bank Holding Company Act’s definition of a bank. That restriction places it within a different framework from conventional banking groups. Affiliate relationships still attract scrutiny: the decision considers restrictions on transactions with related entities. A chartered subsidiary can confer federal prestige on a group, but that reputation alone says little about the supervision of every company within it. ^{2, 13}

Assessing the competitive advantage therefore requires looking at both group and product boundaries: where do the assets, obligations, technical staff and legal responsibilities sit? The lawsuit raises the perimeter question. It does not itself measure the risks actually transferred between each bank and its affiliates. ^{2, 13}

The comparison needs to follow the risks. A custodian safeguarding segregated assets and charging service fees performs a different financial function from a bank funding long-term loans with redeemable deposits. Imposing every obligation of the latter model on the former could shelter incumbents from competition. Conversely, adding trading, customer lending or payment services around custody requires a fresh assessment of the associated exposures. Calling the business custody cannot resolve every question raised by its other functions. ^{6, 13, 25}

A national charter may also displace some state requirements. But preemption is constrained. Section 25b of the US Code includes a test concerning interference with the exercise of a national bank’s powers. Federal status therefore does not erase state law wholesale or automatically extend the same treatment to every affiliate. Its precise competitive value depends on the activity and requirement at issue. ¹⁹

The strongest OCC defence is that a specialised charter can bring an activity under demanding federal supervision, with explicit limits, examinations and enforceable conditions. Protego’s decision gives that argument substance. The strongest criticism asks the agency to demonstrate a sufficient statutory basis and proportionate safeguards, especially as business models expand. ^{5, 13}

As of October 4, 2026, the public sources reviewed establish the filing and the positions already published. No judgment on the merits was identified in those sources. The OCC declined comment to Reuters, but its rules and approval letters explain the agency’s reasoning. Predicting a victory for the banks, cancellation of the new charters or judicial endorsement of the OCC would go beyond the record. ^{36, 4, 5}

The lasting issue is the fit between a label, a business and a promise. An institution can be federally chartered, specialise in custody and lack deposit insurance. That arrangement can be coherent. Customers need to understand it all the way through an intermediary’s failure. Supervisors need to justify it on grounds more durable than enthusiasm for the current technology. The value of the word “bank” ultimately depends on the obligations its customers can enforce.

Sources, method and scope

This documentary investigation is current to October 4, 2026. It draws on ICBA’s published complaint, OCC decisions, statutory texts, FDIC and Federal Reserve publications, and corporate disclosures identified as such. The parties were not contacted for this edition. Allegations remain attributed. The $100 examples are hypothetical teaching examples.

Follow the guarantees and the reserves

The GENIUS Act regulator map explains which authority oversees each part of the framework. Our investigation into stablecoin reserves and redemption delays follows the holder’s claim through to payment. For the interest earned on reserves, read USD1, rates and their beneficiaries.

Source documents

1. S01 · ICBA · 2026-10-02ICBA Sues OCC Over National Trust Bank Charters for Crypto Firms. Complaint announcement and the claimant’s position. Interested source.
2. S02 · ICBA / U.S. District Court for the District of Columbia · 2026-10-02ICBA v. OCC: as-filed complaint, version published by ICBA. Court-stamped complaint, case 1:26-cv-03441, filed October 2, 2026. Paragraph 14 cites the 2021 decision; paragraphs 62 and 65 describe the 2025 application and its February 2026 approval. Prayer for relief on pages 38-39.
3. S03 · Reuters · 2026-10-02Community banks sue US regulator over crypto firm charters. Reuters report on the complaint filing. Full text republished by GV Wire, source 36.
4. S04 · OCC · 2026-02-27National Bank Chartering: Final Rule, OCC Bulletin 2026-4. Amendment to 12 CFR 5.20; regulator presents it as clarification.
5. S05 · OCC / Federal Register · 2026-03-02National Bank Chartering, 91 FR 9977–9982. Final text, responses to comments, and unresolved minimum fiduciary activity question.
6. S06 · OCC · 2021-01-11Interpretive Letter 1176: OCC Chief Counsel’s Interpretation on National Trust Banks. Broad chartering interpretation, signed by Jonathan V. Gould.
7. S07 · U.S. Code / Cornell LII · undated12 U.S.C. §27: Certificate of authority to commence banking. Final sentence of section 27(a), added in 1978.
8. S08 · U.S. Code / Cornell LII · undated12 U.S.C. §92a: Trust powers. Fiduciary powers and interaction with state law.
9. S09 · OCC · undatedComptroller of the Currency: Jonathan V. Gould. Current Comptroller and start of term, checked October 4.
10. S10 · OCC · 2025-03-07Crypto-Asset Activities: Interpretive Letter 1183, OCC Bulletin 2025-2. Rescission of IL 1179 and withdrawal from two 2023 joint statements.
11. S11 · OCC · 2025-05-07OCC Clarifies Bank Authority to Engage in Crypto-Asset Custody and Execution Services. Permissible services for existing banks, including third-party risk management.
12. S12 · OCC · 2025-12-12OCC Announces Conditional Approvals for Five National Trust Bank Charter Applications. Circle and Ripple de novo; BitGo, Fidelity and Paxos conversions. Conditional stage at that date.
13. S13 · OCC · 2026-02-13Corporate Decision 1366: National Digital Trust Company / Protego. Pages 1–3, 7–9, 12–13: activities, conditions and pre-opening examination. Page 8 screenshot checked.
14. S14 · OCC · 2021-02-04Conditional Approval 1259: Protego Trust Company. Earlier decision, distinct from Corporate Decision 1366.
15. S15 · OCC · 2025-12-12Conditional Approval 1358: Paxos Trust Company. Page 3, footnote 7, checked in screenshot: $6.8tn administered, of which $5.2tn fiduciary and $1.6tn custody/safekeeping. All OCC-supervised uninsured national trust banks, not crypto only.
16. S16 · Circle · 2026-07-10Circle Receives Final OCC Approval to Establish National Trust Bank. Initial scope: fiduciary custody for Circle and affiliates. USDC reserve management described as a future capability.
17. S17 · OCC · undatedDigital Assets Licensing Applications. Pending applications only, not a census of approved charters.
18. S18 · FDIC · undatedYour Insured Deposits. Standard $250,000 limit per depositor, insured bank and ownership category; crypto assets excluded.
19. S19 · U.S. Code / Cornell LII · undated12 U.S.C. §25b: State law preemption standards. Constrained preemption; state laws not universally displaced, with separate treatment of affiliates.
20. S20 · U.S. Congress · 2025-07-18GENIUS Act, Public Law 119-27. Sections 2, 4, 13 and 20: issuers, reserves, no federal insurance for tokens and effective-date formula.
21. S21 · OCC · 2026-02-25GENIUS Act: Notice of Proposed Rulemaking, OCC Bulletin 2026-3. Implementation proposal, distinct from final chartering rule.
22. S22 · Treasury / Federal Register · 2026-09-30Forms and Procedures for Review of State Certifications, 91 FR 61688. Procedural rule effective September 30: state-regime certification. Certifications accepted after PRA approval and notification. Expected GENIUS effective date: January 18, 2027.
23. S23 · Federal Reserve Board · 2026-05-20Proposal to establish a payment account. Reserve Banks decide access; unchanged legal eligibility; proposed limited services.
24. S24 · Federal Reserve Board · 2026-05-20Statement on Payment Account Proposal by Governor Michael S. Barr. Dissent on illicit-finance safeguards, distinct from deposit insurance.
25. S25 · Federal Reserve / FEDS Notes · 2025-12-17Banks in the Age of Stablecoins: Some Possible Implications for Deposits, Credit, and Financial Intermediation. Deposit recycling, reserve allocation and concentration; numerical scenarios not reproduced.
26. S26 · Federal Reserve Bank of New York / Lee and Tou · 2026-02Stablecoin Disintermediation, Staff Report 1185. Liquidity channel and partner-bank balance sheets; not an estimate of observed aggregate credit contraction in 2026.
27. S27 · Federal Reserve Bank of New York / Lee and Tou · 2026-02Stablecoin Disintermediation, full paper. Sample limitations and limits on identifying aggregate credit effects.
28. S28 · FDIC · 2023-08-04FDIC Demands Unbanked, Inc. Cease Making False or Misleading Representations about Deposit Insurance. Unbanked example, separate from institutions in the 2026 litigation.
29. S29 · OCC / Federal Register · 2016-12-20Receiverships for Uninsured National Banks, 81 FR 92594. Receivership framework for uninsured national banks; published December 20, 2016, effective January 19, 2017.
30. S30 · eCFR / OCC · undated12 CFR Part 51: Receiverships for Uninsured National Banks. Distinct from FDIC resolution; a legal framework exists, while its operational resilience for complex crypto failures remains to be assessed.
31. S31 · OCC · undatedCommunity Reinvestment Act (CRA). Assessment of community credit needs, including low- and moderate-income areas, for certain insured depository institutions.
32. S32 · OCC · undatedTrust Banks Active as of August 31, 2026. Register as of August 31, 2026 of active trust banks: BitGo, Fidelity Digital Assets, First National Digital Currency Bank and Paxos.
33. S33 · OCC · 2026-06-22GENIUS Act: Anti-Money Laundering/Countering the Financing of Terrorism and Sanctions Compliance: Notice of Proposed Rulemaking. Proposed anti-money-laundering and sanctions requirements for stablecoin issuers.
34. S34 · OCC · 2026-08-19Comptroller Gould Discusses Digital Asset Innovation, GENIUS Next Steps. Jonathan Gould announces a final-rule target by November; an announced timetable, not a final publication.
35. S35 · Federal Reserve Bank of Kansas City · 2026-03-04Federal Reserve Bank of Kansas City Approves Limited Account. Limited account for Payward Financial / Kraken Financial, a Wyoming SPDI, for an initial one-year term. Distinct from the Payward National Trust Company OCC application.
36. S36 · Reuters / GV Wire republication · 2026-10-03Community Banks Sue US Regulator Over Crypto Firm Charters. Full Reuters report by Pete Schroeder; states that an OCC spokesperson declined to comment.