The Big Five Go Banking: How Circle, Ripple, BitGo, Paxos, and Fidelity Are Rewriting the Crypto-Wall Street Relationship
On December 12, 2025, the Office of the Comptroller of the Currency (OCC) did something unprecedented: it conditionally approved five crypto-native companies for national trust bank charters in a single announcement. Circle, Ripple, BitGo, Paxos, and Fidelity Digital Assets—representing over $200 billion in combined stablecoin circulation and digital asset custody—are now one step away from becoming federally regulated banks.
This isn't just another crypto headline. It's the clearest signal yet that digital assets have crossed the regulatory Rubicon, moving from the wild west of financial innovation into the heavily fortified perimeter of American banking.
The Historic Approval: What Actually Happened
The OCC's December announcement marked the first time the agency had granted conditional approvals to multiple crypto-native firms simultaneously. The five companies fall into two categories:
De Novo National Trust Banks (New Charters):
- Circle → First National Digital Currency Bank
- Ripple → Ripple National Trust Bank
State-to-Federal Conversions:
- BitGo Bank & Trust, N.A.
- Fidelity Digital Assets, N.A.
- Paxos Trust Company, N.A.
"New entrants into the federal banking sector are good for consumers, the banking industry and the economy," said Jonathan Gould, the Comptroller of the Currency. "They provide access to new products, services and sources of credit to consumers, and ensure a dynamic, competitive and diverse banking system."
The approvals came remarkably fast—less than six months from filing—signaling the OCC's clear intent to accelerate digital asset integration into the banking system.
Why National Trust Charters Matter
A national trust bank charter might sound like regulatory arcana, but it represents a fundamental shift in how crypto companies can operate. Here's what changes:
What They Can Do
National trust banks are authorized to provide:
- Custody services for digital assets
- Settlement infrastructure for crypto transactions
- Fiduciary services including asset management
- Stablecoin issuance under the GENIUS Act framework
What They Cannot Do
Unlike full-service commercial banks, national trust banks:
- Cannot accept FDIC-insured deposits
- Cannot make traditional loans
- Cannot offer checking or savings accounts
The Real Value: Federal Preemption
The killer feature of a national trust charter isn't about new capabilities—it's about regulatory simplification. Before this, a crypto company wanting to operate nationwide faced a nightmare scenario: obtaining 50+ state money transmitter licenses, each with different requirements, timelines, and renewal processes.
With a national trust charter, companies operate under one federal regulator (the OCC), with federal preemption of state licensing requirements. It's the difference between navigating a maze and walking down a corridor.
The GENIUS Act Connection
The December approvals didn't happen in a vacuum. They're intimately connected to the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins), signed into law by President Trump on July 18, 2025.
The GENIUS Act created the first comprehensive federal framework for stablecoins, and critically, it designated national trust banks as permitted stablecoin issuers. This means the newly chartered crypto banks can:
- Issue compliant stablecoins backed 1:1 by approved reserves (dollars, short-term Treasuries, repos)
- Operate nationwide without additional state licensing
- Escape securities classification—payment stablecoins under the GENIUS Act are explicitly not securities or commodities
The reserve requirements are strict: permitted assets include only U.S. dollars, deposits at insured banks, short-dated Treasury bills, repos backed by Treasuries, government money market funds, and central bank reserves. No algorithmic mechanisms, no exotic collateral.
Meet the Big Five
Each of the approved companies brings a distinct business model and market position:
Circle: The Stablecoin Giant
Circle issues USDC, the second-largest stablecoin with approximately $45 billion in circulation. Its new charter as "First National Digital Currency Bank" positions it to expand USDC's reach into traditional banking channels while maintaining the reserve transparency that has become its competitive advantage.
Ripple: From Payments to Banking
Ripple's approval as "Ripple National Trust Bank" is particularly significant given the company's history. After years of regulatory battles with the SEC, Ripple is now positioning itself as a federally regulated provider of cross-border payment and custody infrastructure. CEO Brad Garlinghouse called the approval "a massive step forward," taking a direct shot at banking industry lobbying efforts that opposed the charters.
BitGo: Institutional Custody Leader
BitGo has been the quiet giant of crypto custody, safeguarding digital assets for institutional clients since 2013. Its conversion from a state trust company to a national trust bank expands its ability to serve large institutions requiring federally regulated custodians.
Paxos: The White-Label Infrastructure Play
Paxos has quietly become the plumbing behind many crypto products you've probably used without knowing it. The company powers PayPal's crypto offering and issues USDP stablecoin. Federal charter status strengthens its position as the preferred infrastructure provider for traditional financial institutions entering crypto.
Fidelity Digital Assets: TradFi's Crypto Vanguard
Fidelity was early to crypto among traditional finance giants, launching its digital asset custody service in 2018. Converting to a national trust bank charter signals its commitment to making crypto custody a core business line alongside its $14 trillion in traditional assets under administration.
The Pipeline: Who's Next?
The OCC's approval of five firms is just the beginning. Several major players have applications pending:
- Coinbase — seeking to expand its institutional custody capabilities
- Crypto.com (Foris DAX National Trust Bank) — pursuing U.S. expansion
- Bridge (Stripe's stablecoin orchestration affiliate) — following Stripe's $1.1 billion acquisition
- Nubank — Brazil's largest neobank
- Sony's Connectia — entering digital asset services
Meanwhile, Anchorage Digital remains the only crypto-native company to hold a full federal bank charter (obtained in January 2021). The five new conditional approvals bring the total to six federally regulated crypto banks—with more on the way.
Traditional Banks Fight Back
Not everyone is celebrating. The American Bankers Association (ABA) warned that the approvals "could blur the lines of what it means to be a bank and create opportunities for regulatory arbitrage."
The Bank Policy Institute (BPI) issued a statement expressing concerns about competitive fairness, arguing that crypto firms with national trust charters gain banking privileges without the full regulatory burden faced by traditional banks.
These concerns aren't entirely without merit. National trust banks:
- Are not regulated at the holding company level
- Don't face the full suite of banking regulations
- Benefit from federal preemption without FDIC insurance requirements
The counterargument: they also can't take deposits or make loans—the core activities that create systemic risk in traditional banking.
What This Means for the Market
For Institutions
The barrier to institutional crypto adoption just got significantly lower. CFOs and treasurers can now work with federally regulated counterparties for:
- Stablecoin settlements — faster, cheaper than traditional wire transfers
- Digital asset custody — with the regulatory clarity institutional compliance teams demand
- Cross-border payments — particularly via Ripple's new banking infrastructure
For Stablecoin Users
USDC, USDP, and any new stablecoins from the chartered banks will operate under a clear federal framework. The GENIUS Act's 1:1 reserve requirements and monthly attestation requirements provide stronger guarantees than the current patchwork of state regulations.
For the Broader Crypto Ecosystem
The OCC's willingness to process applications quickly—within 120 days for complete applications—signals an open window for well-prepared applicants. Expect more crypto companies to pursue federal charters in 2026, particularly those with institutional ambitions.
The Bigger Picture: Crypto Enters the Banking Perimeter
The December 2025 approvals represent a fundamental shift in how regulators view digital assets. For years, the debate was whether crypto belonged in the financial system at all. That debate is over.
The new question is how deeply integrated crypto will become. The OCC has now issued several interpretive letters clarifying what banks can do with crypto:
- IL 1183 (March 2025): Banks can offer crypto custody, stablecoin services, and network participation without prior approval
- IL 1184 (May 2025): Banks can buy and sell custodied crypto on behalf of customers
- IL 1188 (December 2025): Banks can execute "riskless principal" crypto transactions
Each letter removes friction, making it easier for traditional banks to offer crypto services and for crypto companies to operate like banks.
Looking Ahead: 2026 and Beyond
The OCC isn't done. On January 8, 2026, the agency issued a Notice of Proposed Rulemaking that would clarify and potentially expand permissible activities for national trust banks. The proposal would confirm that trust banks can engage in activities "related to" traditional trust activities—language that could open doors for additional digital asset services.
Meanwhile, the FDIC has approved its own NPRM establishing procedures for FDIC-supervised institutions to issue payment stablecoins through subsidiaries. The regulatory infrastructure for bank-issued stablecoins is being built in real-time.
Five years from now, the distinction between "crypto companies" and "banks" may be meaningless. The Big Five's federal charters are the first major step toward that convergence.
Conclusion
The OCC's conditional approval of Circle, Ripple, BitGo, Paxos, and Fidelity Digital Assets for national trust bank charters is a watershed moment for digital assets. It's not just regulatory acceptance—it's an invitation into the banking system itself.
For investors, builders, and users, the implications are profound:
- Stablecoins are no longer in regulatory limbo—they're part of the banking perimeter
- Institutional adoption has a clear path forward through federally regulated counterparties
- The competitive landscape is shifting from pure crypto players to a hybrid of crypto-natives and traditional finance
The Big Five have crossed the threshold. The only question now is who follows them through the door.
BlockEden.xyz provides enterprise-grade blockchain API infrastructure supporting institutions navigating the evolving regulatory landscape. As digital assets integrate deeper into traditional finance, reliable node infrastructure becomes critical for stablecoin operations, custody solutions, and settlement systems. Explore our API marketplace to build on infrastructure designed for institutional requirements.