Can US banks now hold and custody crypto like XRP?

The full answer

What has the OCC said national banks may do with crypto?

On May 7, 2025, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter 1184, according to a memo the law firm Sullivan & Cromwell published on May 9, 2025 [1]. The memo says the letter clarifies that national banks and federal savings associations may buy and sell assets held in custody at the custody customer’s direction, consistent with the customer agreement and applicable law [1]. The memo also says banks may outsource bank-permissible crypto-asset activities, including custody and execution services, to third parties such as sub-custodians, subject to third-party risk management [1].

The law firm Davis Wright Tremaine describes a separate OCC clarification on network fees [2]. Distributed-ledger networks charge fees in the network’s own native crypto-asset [2]. The firm says a national bank may pay those fees, or hold a small amount of the native tokens needed to pay them, to the extent needed for reasonably foreseeable fees or to test otherwise permissible platforms [2]. The firm also notes that many banks already have the operational capacity to buy, sell and hold crypto-assets for custody, stablecoin or other permissible activities [2]. On the XRP Ledger, every transaction burns a tiny amount of XRP as a fee, crypto.news reported on July 8, 2026 [9].

Neither law-firm description names XRP [1][2]. The permissions apply to crypto-assets in general (Analysis, from [1] and [2]).

The OCC said the letter confirms “that crypto-asset custody, certain stablecoin activities, and participation in independent node verification networks such as distributed ledger are permissible for national banks and federal savings associations.”[10]

The letter “rescinds the requirement for OCC-supervised institutions to receive supervisory nonobjection and demonstrate that they have adequate controls in place before they can engage in these cryptocurrency activities.”[10] The standard stayed: “The OCC expects banks to have the same strong risk management controls in place to support novel bank activities as they do for traditional ones.”[10]

On March 28, 2025, in FIL-7-2025, the Federal Deposit Insurance Corporation said the banks it supervises “may engage in permissible crypto-related activities without receiving prior FDIC approval,” provided “that they adequately manage the associated risks.”[11]

It said it “will instead monitor banks’ crypto-asset activities through the normal supervisory process.”[12]

It reminds banks they “must do so in a safe and sound manner” and says it “does not create any new supervisory expectations.”[13]

The new statement “creates an avenue” for those banks “to engage in certain innovative activities.”[14]

Does any US bank hold XRP today?

Yes, at least one. The quarterly filing of the TOXR XRP trust, for the period to June 30, 2026, says Coinbase, BitGo and Anchorage Digital Bank N.A. are its custodians and hold all of the trust’s XRP [3]. On June 30, 2026 the trust held 108,256,464.0739 XRP with a fair value of $112,922,318, according to the same filing [3]. CoinDesk reported on July 2, 2025 that crypto custodian Anchorage Digital already held a federal charter [4].

Large banks have started crypto custody for other assets. Schwab announced in its press release that Charles Schwab Premier Bank, SSB, Member FDIC, offers the crypto products and will serve as custodian of clients’ digital assets, with Paxos set to deliver sub-custody and trade execution (company-reported) [5]. Schwab said trading at launch covers bitcoin and ethereum, and that it plans to add other cryptocurrencies over time [5]. The announcement does not name XRP [5]. A wider survey of which institutions hold XRP for clients is on the page Can regulated institutions safely custody XRP?.

SEC Release 33-11412, effective March 23, 2026, lists “XRP (XRP)” as an example of a digital commodity.[17] On July 13, 2023 CoinDesk reported that Coinbase said it “will re-enable trading for XRP” and that Bitstamp said it had “resumed trading of XRP in the United States effective immediately.”[18]

Do FDIC-supervised banks and Federal Reserve member banks still need approval?

As of October 1, 2026, the FDIC’s and the Federal Reserve’s 2025 statements on prior approval or advance notice for crypto activity, and the text of OCC Interpretive Letter 1183, have not been reviewed for this page. This page makes no claim about what those documents say. The Schwab example above is an FDIC-member bank that Schwab said, in its press release, will serve as custodian of clients’ digital assets (company-reported) [5].

Does permission to custody mean a bank can lend against XRP?

No. Custody and collateral are separate questions (Analysis, from [1] and [9]). crypto.news reported on July 8, 2026 that Ripple Prime accepts XRP as collateral for margin within its own brokerage, which the outlet called Ripple’s own brokerage accepting Ripple’s own asset [9]. For that to matter at scale, firms that are not Ripple would need to accept and hold XRP as margin, which crypto.news says requires the legal certainty of commodity classification plus risk-committee approval at each institution [9]. The tests a lender applies are covered in Does XRP meet the tests for institutional collateral?, and the balance-sheet cost is covered in What rules govern lending against XRP, and how do bank capital rules treat it?.

Where does Ripple’s own trust bank charter stand?

CoinDesk reported that Ripple applied for a national bank charter with the OCC on July 2, 2025, and for a Federal Reserve master account earlier that week through its subsidiary Standard Custody [4]. On December 12, 2025 the OCC granted Ripple National Trust Bank preliminary conditional approval [6]. The approval letter says the bank plans to provide cryptocurrency custody to affiliates and unaffiliated institutional customers on a fiduciary basis [6]. It must limit its operations to those of a trust company and hold at least $11.7 million in tier 1 capital, and it will not be an insured depository institution [6].

Final approval to open will not be granted until all preopening requirements are met [6]. The approval expires if capital is not raised within 12 months or the bank does not open within 18 months [6]. Counted from December 12, 2025, those dates are December 12, 2026 and June 12, 2027 (our count from [6]). The OCC says it is opposed to granting extensions except under the most extenuating circumstances [6]. Until final approval, the OCC can modify, suspend or rescind the approval [6]. Ripple itself wrote in September 2026 that this is a conditional approval, one step in a multi-stage federal chartering process, not a completed charter [7]. More detail is on Is Ripple becoming a bank (Ripple National Trust Bank)?.

Federal Reserve Governor Michael Barr dissented from the December 2025 change: “I cannot agree to rescind the current policy statement and adopt a new one that would, in effect, encourage regulatory arbitrage, undermine a level playing field, and promote incentives misaligned with maintaining financial stability.”[15]

What is the case against treating this as settled?

The permissions come from agency letters, and the strongest objection is political. crypto.news reported on May 27, 2026 that Senator Elizabeth Warren and banking groups challenged the idea that crypto firms with OCC trust charters should be treated like bank-grade institutions, arguing they could act like crypto banks without the same restrictions [8]. Ripple’s own charter remains conditional and revocable by the OCC until final approval [6]. Whether a later government could undo these positions is covered in Could a future US government reverse XRP’s regulatory position?. Whether bank custody protects an individual holder better than a crypto platform is covered in What happens to my XRP if the exchange goes bankrupt?.

Troutman Pepper Locke wrote on September 25, 2026 that agency action “is subject to direction under future administrations, which could revise or withdraw rules and interpretations.”[16] The case that the current position could reverse is on could XRP’s regulatory position reverse.