Can regulated institutions safely custody XRP?
Also asked as: “Is institutional custody of XRP a solved problem?” · “Can regulated U.S. institutions custody XRP?” · “Is XRP custody legal, operational and at institutional scale?”
Confirmed Published 6 min read
Short answer
Yes, regulated trust companies already hold XRP for exchange-traded funds. Canary XRP ETF’s quarterly filing reported 231,279,303 XRP held at June 30, 2026, with Coinbase Custody Trust Company and BitGo Trust Company as custodians. Ripple’s own trust bank had only preliminary conditional approval from the OCC on December 12, 2025, and may not open until final approval.
The full answer
Which custodians hold XRP, and under which charters or licences?
The clearest evidence is in the filings of the US spot XRP funds. Canary XRP ETF’s Form 10-Q for the quarter to June 30, 2026 names Coinbase Custody Trust Company, LLC and BitGo Trust Company, Inc. as the custodians responsible for safekeeping the trust’s XRP [1]. The same filing lists 231,279,303 XRP with a fair value of $241,278,596 at June 30, 2026 [1].
21Shares XRP ETF (ticker TOXR) reported 108,256,464.0739 XRP with a fair value of $112,922,318 at June 30, 2026 [2]. Its report names Coinbase, BitGo and Anchorage Digital Bank N.A. as the custodians that hold all of the trust’s XRP on its behalf [2]. The 21Shares product page, which shows performance as of September 29, 2026, lists the fund custodians as Anchorage Digital Bank N.A., BitGo Bank & Trust, N.A. and Coinbase Custody International, Ltd [3].
Bitwise XRP ETF’s quarterly report for the first quarter of 2026 names Coinbase Custody Trust Company, LLC, which it describes as a New York State limited liability trust company, as custodian for XRP for which qualified custody is available [4]. The XRP sits in a custody account in the trust’s name [4].
| Fund | Custodians named | XRP held | Date |
|---|---|---|---|
| Canary XRP ETF | Coinbase Custody Trust; BitGo Trust [1] | 231,279,303 [1] | June 30, 2026 |
| 21Shares XRP ETF (TOXR) | Coinbase; BitGo; Anchorage Digital Bank N.A. [2] | 108,256,464 [2] | June 30, 2026 |
The two dated holdings add up to about 339.5 million XRP with custodians at June 30, 2026, before Bitwise is counted. How that figure has moved is tracked in How much XRP do the US spot XRP ETFs hold, and is it growing?, and whether the funds hold the token itself is covered in Do XRP ETFs hold real XRP, or is it synthetic exposure?.
On charters: on December 12, 2025 the OCC conditionally approved BitGo Bank & Trust, Fidelity Digital Assets and Paxos Trust Company to convert from state trust companies to national trust banks [5]. The project’s sources do not confirm when, or whether, BitGo’s conversion was completed.
What have US bank regulators allowed?
On May 7, 2025 the OCC issued Interpretive Letter 1184. According to a Sullivan & Cromwell memo dated May 9, 2025, it clarifies that national banks and federal savings associations may buy and sell assets held in custody at the customer’s direction, and may outsource crypto-asset custody and execution to third parties, including sub-custodians, subject to third-party risk management [6].
The OCC’s December 12, 2025 release conditionally approved de novo national trust bank charters for First National Digital Currency Bank and Ripple National Trust Bank, alongside the three conversions above [5]. The OCC said that, subject to its conditions, these institutions would join approximately 60 other national trust banks it supervises [5]. The OCC’s release adds that, as of September 30, 2025, OCC-supervised uninsured national trust banks held $1.6 trillion in custody assets [7].
Where does Ripple’s own trust bank stand?
The letter says the bank plans to provide cryptocurrency custody to affiliates and unaffiliated institutional customers on a fiduciary basis, and that its custody services will be subject to fiduciary duties and standards of behavior [7]. It must limit its operations to those of a trust company, hold at least $11.7 million in tier 1 capital, and will not be an insured depository institution [7].
Final approval to begin business will not be granted until all preopening requirements are met, and until then the OCC may modify, suspend or rescind the approval [7]. The approval expires if capital is not raised within 12 months or the bank does not open within 18 months of the approval date [7]. Counted from December 12, 2025, those deadlines fall on December 12, 2026 and June 12, 2027. Ripple’s wider licence set is listed in Which licences does Ripple hold to run payments, custody and stablecoins, and where?.
Ripple Custody is a separate product that supplies wallet infrastructure to banks. On April 30, 2026 Ripple announced a partnership with Kbank, which Ripple describes as Korea’s first internet-only bank, to deploy institutional digital asset wallet infrastructure through Ripple Custody [8]. Kbank’s chief executive said the partnership advances the bank’s stablecoin-based remittance capabilities [8]. Other Ripple Custody clients are covered in What is Ripple Custody, and which banks use it?.
Does custody put XRP to work, or only store it?
crypto.news reported on July 8, 2026 that Ripple Prime accepts XRP as collateral for margin and settlement within its own brokerage, and that for collateral demand to matter at scale, firms that are not Ripple would need to accept and hold XRP as margin [9]. A Cheeky Crypto video summary posted on KuCoin on September 22, 2026 says XRP fund collateral reportedly grew from roughly $36,000 in April to at least $8.3 million by August [10]. The same summary says collateral acceptance adds zero direct XRP demand, and that XRP buying only happens when new fund shares are created [10]. The repo evidence is examined in Are XRP ETF shares being used as repo collateral, and did Schwab buy XRP?.
IL 1184 gives banks legal room to trade custodied assets on instruction, so a custody account can connect to lending, collateral or trading. The evidence to date shows that link running mainly inside Ripple’s own businesses or at small scale. The route from a custodian’s vault into on-chain protocols is covered in Can XRP held with an institutional custodian be put to work in DeFi?.
Has any regulated custodian lost client XRP?
This page cites no record of a regulated custodian losing client XRP, but it documents no systematic search either. That is a gap in what I could find, not proof that no loss has occurred. The filings describe controls rather than a loss record. Bitwise’s report notes that temporary differences between the XRP held by its custodian and the amount in its financial statements may occur because of pending trade settlement, which generally occurs within two business days [4]. The OCC letter requires Ripple National Trust Bank to purchase adequate fidelity bond coverage [7]. What happens to client assets when a platform itself fails is covered in What happens to my XRP if the exchange goes bankrupt?.
What is the strongest case against reading custody as progress for XRP?
crypto.news (July 8, 2026) wrote that skeptics do not deny the infrastructure is real; they deny that infrastructure ownership by the token’s issuer, absent third-party adoption, constitutes token demand, and that on the evidence to date they have been right [9]. The same article says Ripple Prime’s revenues belong to Ripple’s shareholders, not to XRP, and that the same is true of custody fees [9].
Custody is also not offered for XRP everywhere. Charles Schwab’s 2026 spot crypto announcement said Schwab Crypto would provide direct access to bitcoin and ethereum trading, with Paxos, which Schwab describes as OCC-regulated, delivering sub-custody and trade execution [11]. Custody working for XRP at Coinbase, BitGo and Anchorage shows the task is solved technically and legally for those firms; it does not show that every regulated channel offers XRP, or that custodied XRP creates new demand. Which other parts of the stack are running is set out in Which parts of the XRP institutional stack are live today, and which are still waiting?.
What we know
- Canary XRP ETF’s Form 10-Q for the quarter to June 30, 2026 names Coinbase Custody Trust Company, LLC and BitGo Trust Company, Inc. as the custodians responsible for safekeeping the trust’s XRP, and lists 231,279,303 XRP with a fair value of $241,278,596 at June 30, 2026.
- 21Shares XRP ETF (TOXR) reported 108,256,464.0739 XRP with a fair value of $112,922,318 at June 30, 2026, held by its custodians Coinbase, BitGo and Anchorage Digital Bank N.A.
- Bitwise XRP ETF’s quarterly report for the first quarter of 2026 names Coinbase Custody Trust Company, LLC, a New York State limited liability trust company, as its XRP custodian, with the XRP held in a custody account in the trust’s name.
- On May 7, 2025 the OCC issued Interpretive Letter 1184. Sullivan & Cromwell (May 9, 2025) reports that it lets national banks buy and sell custodied assets at the customer’s direction and outsource crypto custody to sub-custodians, subject to third-party risk management.
- On December 12, 2025 the OCC conditionally approved a national trust bank charter for Ripple National Trust Bank and conditional conversions of BitGo, Fidelity Digital Assets and Paxos from state trust companies to national trust banks.
- The OCC’s December 12, 2025 letter says Ripple National Trust Bank plans fiduciary crypto custody for affiliates and unaffiliated institutional customers, must hold at least $11.7 million in tier 1 capital, will not be an insured depository institution, and cannot begin business until all preopening requirements are met.
- On April 30, 2026 Ripple announced that Kbank would deploy wallet infrastructure through Ripple Custody (Ripple’s announcement).
- crypto.news (July 8, 2026) reports that Ripple Prime accepts XRP as collateral within its own brokerage.
- A Cheeky Crypto video summary posted on KuCoin on September 22, 2026 says XRP fund collateral reportedly grew from roughly $36,000 in April to at least $8.3 million by August, and that collateral acceptance adds zero direct XRP demand.
- Charles Schwab’s 2026 spot crypto announcement offered direct trading in bitcoin and ethereum, with Paxos delivering sub-custody and trade execution.
What we reason Analysis
- The Canary and 21Shares filings together show about 339.5 million XRP (231,279,303 plus 108,256,464) held with custodians at June 30, 2026, before counting Bitwise, whose holding figure was not found in its filing.
- Custody of XRP for listed funds is operational at three custodian groups (Coinbase, BitGo, Anchorage) as of mid-2026. This follows from the three funds’ filings and the 21Shares product page.
- The safety case rests on structure (segregated accounts in the fund’s name, trust-company and fiduciary frameworks) more than on a track record, because no loss record, clean or otherwise, is public. This follows from the gap search.
- Custody can act as a gateway to other uses: IL 1184 lets banks trade custodied assets at the customer’s direction, and Ripple Prime already takes XRP as collateral. The evidence so far shows that use is internal to Ripple or small, and ETF-share collateral does not itself buy XRP.
- Counting from December 12, 2025, Ripple National Trust Bank must raise its capital by December 12, 2026 and open by June 12, 2027 or the approval expires.
- Availability of XRP custody at some trust companies does not mean every regulated channel offers XRP: Schwab’s own spot launch covered bitcoin and ethereum only.
What's still open
- As of September 30, 2026, I could not find any OCC final approval for Ripple National Trust Bank to begin business.
- As of September 30, 2026, no public document confirms that BitGo’s conversion to a national trust bank has been completed, although the 21Shares product page uses the name BitGo Bank & Trust, N.A.
- As of September 30, 2026, I could not find any report of a regulated custodian losing client XRP. This is a search gap, not proof that no loss has occurred.
- Whether Canary XRP ETF’s custodians changed after June 30, 2026 is not confirmed.
- Bitwise XRP ETF’s XRP holding figure is not in the saved passages of its filing as of September 30, 2026.
In plain English
Big investment funds that hold XRP do not keep it themselves. They pay specialist trust companies, such as Coinbase Custody and BitGo, to guard it in accounts in the fund’s name, and one fund alone reported about 231 million XRP held this way in mid-2026. US bank regulators have said banks can do this kind of work, and Ripple has early, conditional permission to open its own trust bank. What the public record cannot yet show is a long history of how these custodians perform when something goes wrong.
Key terms
Sources
- Canary XRP ETF Form 10-Q, quarter ended June 30, 2026 — U.S. Securities and Exchange Commission (EDGAR), 2026-08 Primary
- 21Shares XRP ETF 10-Q quarterly report — Stock Titan (SEC filing text), Tue Jun 30 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Primary
- 21Shares XRP ETF (TOXR) product page — 21Shares, Tue Sep 29 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Company-reported
- Bitwise XRP ETF 10-Q quarterly report — Stock Titan (SEC filing text), Tue Mar 31 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Primary
- OCC Conditionally Approves National Trust Bank Charters (NR 2025-125) — Office of the Comptroller of the Currency, Fri Dec 12 2025 00:00:00 GMT+0000 (Coordinated Universal Time) Primary
- OCC Clarifies Bank Authority to Engage in Crypto Custody and Execution Services — Sullivan & Cromwell LLP, Fri May 09 2025 00:00:00 GMT+0000 (Coordinated Universal Time) Secondary
- Conditional approval letter: Ripple National Trust Bank — Office of the Comptroller of the Currency, Fri Dec 12 2025 00:00:00 GMT+0000 (Coordinated Universal Time) Primary
- Ripple Partners with Kbank to Deploy Scalable Digital Asset Wallet Infrastructure through Ripple Custody — Ripple, Thu Apr 30 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Company-reported
- Ripple Prime cleared $3 trillion: how much of it actually touches XRP? — crypto.news, Wed Jul 08 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Secondary
- Banks Taking XRP As Collateral Won't Buy Your Coins (Cheeky Crypto) — KuCoin News, Tue Sep 22 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Secondary
- Charles Schwab Announces Details of Spot Crypto Trading Launch — Charles Schwab, Thu Apr 16 2026 00:00:00 GMT+0000 (Coordinated Universal Time) Company-reported
- Ripple Secures Federal Approval to Establish National Trust Bank — Ripple, Dec 12, 2025 Company-reported
- What Actually Makes a Stablecoin Regulated: A Guide for Institutions Evaluating RLUSD — Ripple, September 11, 2026 Company-reported
- Form 10-K Annual Report for fiscal year ended December 31, 2025 — BitGo Holdings, Inc. (SEC filing), read 2026-10-02 Primary
- Interpretive Letter #1184: Clarification of Bank Authority Regarding Crypto-Asset Custody Services — Office of the Comptroller of the Currency, May 7, 2025 Primary
- Ripple Prime: Prime Brokerage Products for Institutions — Ripple, read 2026-10-02 Company-reported
- Application to Charter Ripple National Trust Bank, New York, New York (Proposed) and Request to Waive Residency Requirements — Office of the Comptroller of the Currency, December 12, 2025 Primary
- Conditional Approval #1359 — Office of the Comptroller of the Currency, December 12, 2025 Primary
- BitGo Secures Full Unconditional OCC Approval to Convert to a Federally Chartered National Trust Bank — BitGo, Dec 13, 2025 Company-reported
- Corporate Applications Search (CAS) | OCC — Office of the Comptroller of the Currency, read 2026-10-03 Primary
- Amendment No. 4 to Form S-1 Registration Statement (BitGo Holdings, Inc.) — U.S. Securities and Exchange Commission / BitGo Holdings, Inc., January 12, 2026 Primary
Update log
- — Published.
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