American Bankers Association Press OCC to Sequence Crypto Charters Behind Stablecoin Rules

The American Bankers Association (ABA) has called on the Office of the Comptroller of the Currency (OCC) to slow the approval of crypto-related bank charters, warning that advancing applications before Congress finalizes digital asset legislation could pose risks to the financial system.

In a comment letter submitted Wednesday, the ABA urged the OCC to ensure that “robust, broadly applicable safety and soundness standards” are clearly established and consistently applied during what it described as a period of rapid financial innovation. The group recommended that the regulator pause or lengthen its charter decision process while regulatory frameworks for stablecoins and other digital asset activities remain incomplete.

Charter Applications and Regulatory Uncertainty

The letter comes as several crypto-native firms—including Circle, Ripple, BitGo, Paxos, Coinbase, and Nomura’s Laser Digital—either pursue or hold conditional national trust bank charters from the OCC. World Liberty Financial, a crypto firm linked to former President Donald Trump, has also applied for an OCC charter tied to its USD1 stablecoin.

The ABA criticized the OCC’s recent practice of conditioning charter approvals on applicants’ compliance with the GENIUS Act, arguing that the law’s “full regulatory implementation is likely years away” and still depends on rulemaking by multiple federal agencies.

The association urged the OCC to avoid measuring crypto charter applications against traditional approval timelines, stating that regulators should allow each applicant’s full regulatory obligations and risk profile to “come fully into view” before advancing approvals.

Resolution Risk and Institutional Safeguards

The banking lobby also raised concerns about resolution and insolvency risk, citing the collapses of FTX and Celsius in 2022 as examples of failures involving novel business models that challenged existing regulatory tools.

The ABA called on the OCC to ensure its receivership authorities and resolution frameworks are sufficient to address potential insolvencies involving crypto-focused charter holders, should they fail.

In addition, the association urged regulators to prohibit non-bank trust companies from using the term “bank,” arguing that such branding could misrepresent the nature of the institution and the services it provides.

Broader Policy and Market Structure Implications

The letter reflects a broader effort by banking trade groups to influence how crypto firms enter federally regulated finance. Last month, the ABA’s Community Bankers Council warned lawmakers that some crypto companies were circumventing the GENIUS Act’s restrictions on stablecoin interest payments by routing rewards through affiliated platforms.

That dispute has spilled into negotiations over the broader crypto market structure bill, where disagreements over stablecoin yield provisions have stalled progress. The latest draft includes language prohibiting crypto firms from offering any form of yield or interest on stablecoin holdings.

Following the inclusion of that language, Coinbase CEO Brian Armstrong withdrew support for the bill ahead of a Senate Banking Committee markup, stating that the proposed framework would be “materially worse than the current status quo.”