Is Ripple becoming a bank (Ripple National Trust Bank)?

The full answer

Ripple is part of the way through becoming a regulated US trust bank. On December 12, 2025 the Office of the Comptroller of the Currency (OCC) “conditionally approved applications for de novo national trust bank charters for First National Digital Currency Bank and Ripple National Trust Bank.”[1] Conditional approval is a first step. The bank cannot open for business until the OCC grants final approval, and no final approval was found in searches of the OCC’s releases, news coverage and occ.gov on September 29, 2026.

What did the OCC approve on December 12, 2025?

The OCC conditionally approved five national trust bank charter applications that day. Two were new charters: Ripple National Trust Bank and First National Digital Currency Bank, which Circle later named as its bank.[5] Three were conversions of existing state trust companies: BitGo, Fidelity Digital Assets and Paxos. The OCC said that, subject to meeting its conditions, they would join “approximately 60 other national trust banks currently supervised by the OCC.”[1]

Ripple Labs applied in July 2025, according to CoinDesk.[4] Ripple’s own release on the approval uses the word “conditional”, which matches the OCC.[3]

What would the trust bank do, and what could it not do?

The OCC’s letter describes a narrow business. The bank plans to manage the reserve behind RLUSD, Ripple’s stablecoin, for another Ripple subsidiary, Standard Custody & Trust Company. It would also act as collateral trustee for RLUSD holders and “provide cryptocurrency custody service to affiliates and unaffiliated institutional customers on a fiduciary basis.”[2]

The letter also sets a limit: “The Bank must limit its operations to those of a trust company and activities related thereto, as specifically stated in the business plan.”[2] The same condition says the bank must not meet the definition of “bank” under section 2©(1)-(2) of the Bank Holding Company Act. Ripple says the change would put RLUSD under trust oversight from both New York’s Department of Financial Services and the OCC.[3] Ripple’s custody product is covered on what Ripple Custody is.

What still has to happen before it opens?

Final approval, the letter says, “will not be granted until all preopening requirements are met.”[2] The letter adds that until final approval is granted, the OCC has the right to modify, suspend, or rescind the preliminary conditional approval should it deem any interim development to warrant such action. One of the letter’s conditions is capital: at least $11.7 million in tier 1 capital, with a set share held in liquid assets.[2] The letter also says the bank “will not be an insured depository institution”, meaning its deposits would not be insured by the FDIC.[2] In April 2026, 24/7 Wall St. reported that the bank “hasn’t opened for business yet” and still had to meet the OCC’s pre-opening conditions. The OCC letter’s conditions include submitting a letter at least 60 days before the scheduled opening, notifying the OCC that all conditions for a national bank charter have been met, requesting a preopening examination and giving the anticipated opening date. It also requires the bank to submit a description of its final information systems and operations architecture for review and a prior written determination of no supervisory objection. The same article’s headline said the bank’s status had gone live, but the article was describing an OCC final rule that took effect on April 1, 2026, not the bank opening.[8]

What happens if the trust bank does not open before its deadline?

The approval has a time limit. In the OCC’s words: “If the capital for the Bank is not raised within 12 months or if the Bank is not opened for business within 18 months from the preliminary conditional approval date, this approval expires.”[2] Counting from December 12, 2025, that is December 12, 2026 for capital and June 12, 2027 for opening. The letter also says the OCC is opposed to granting extensions, except under the most extenuating circumstances and when the OCC determines that the delay is beyond the applicant’s control. The letter describes the RLUSD issuer, Standard Custody & Trust Company, as a New York limited purpose trust company regulated by the state’s Department of Financial Services, a status separate from the OCC approval.[2]

Has Ripple applied for a Federal Reserve master account, and what would one allow?

CoinDesk reported on July 2, 2025 that Ripple applied for a Federal Reserve master account “via Standard Custody, the New York-based trust and custody firm Ripple acquired last year.”[4] In an X post quoted by CoinDesk, Ripple CEO Brad Garlinghouse said of the charter application: “If approved, we would have both state (via NYDFS) and federal oversight, a new (and unique) benchmark for trust in the stablecoin market.” CoinDesk explained that “Master accounts allow banks and depository institutions to directly access the Federal Reserve, rather than require them to go through intermediary banks”, and that one would let Ripple hold stablecoin reserves such as Treasuries with the central bank.[4]

A master account is a separate decision from the OCC charter, made by the Federal Reserve. According to CoinDesk’s July 2, 2025 report, Ripple CEO Brad Garlinghouse said the company had applied for a Federal Reserve master account through Standard Custody earlier that week. As of CoinDesk’s July 2, 2025 report, no decision had been announced on that application. Whether banks in general may hold crypto for customers is covered on whether US banks can custody crypto.

How far have the other banks approved that day got since conditional approval?

Circle is the closest comparison. According to CoinDesk’s July 2, 2025 report, Circle filed for a similar national banking license earlier that week. On July 10, 2026 Circle announced that it had received OCC approval to establish First National Digital Currency Bank, N.A., which will operate as Circle National Trust.[5] The law firm Davis Wright Tremaine described this as final approval in an August 5, 2026 review.[6] No announcement of the same step by Ripple was found in news and occ.gov searches on September 29, 2026, about nine and a half months after approval.

What do critics of these charters say?

The Independent Community Bankers of America opposed all five December 2025 approvals. It said the firms “are seeking the benefits of a U.S. bank charter without satisfying the full scope of U.S. bank regulations”, and that “Trust banks are not required to meet the same kinds of regulatory and capital standards that apply to federally insured full-service banks.”[7] The ICBA speaks for community banks, and its statement is an argument, not a ruling.

The business plan passages quoted from the OCC letter above cover RLUSD’s reserve and institutional crypto custody, and none of them mention XRP.[2] Whether a trust bank would lift XRP demand is discussed on whether Ripple’s success helps XRP. For the other side, see whether XRP is used as collateral today.