Circle, the company behind USDC, has secured conditional approval from the Office of the Comptroller of the Currency to establish First National Digital Currency Bank, N.A. The OCC granted the charter on December 12, 2025, giving Circle a federally regulated vehicle to manage the reserves backing roughly $62 billion worth of the world’s second-largest stablecoin.
What the charter actually does
The new bank, designated as Charter #25361 and headquartered in New York, is structured as a de novo national trust bank. In English: it’s a brand-new, federally chartered institution built specifically for a narrow set of trust and fiduciary functions, not a full-service bank where you’d open a checking account.
First National Digital Currency Bank will manage USDC reserves on a fiduciary basis for Circle’s US issuer. It will also serve as collateral trustee and provide digital asset custody services to Circle’s affiliates.
The charter explicitly does not permit deposit-taking or any FDIC-insured activities.
Circle originally filed its application on June 30, 2025. The roughly five-and-a-half-month turnaround from application to conditional approval is notable in a regulatory environment that has historically moved at glacial speed when crypto is involved.
The company also plans to establish a separate limited-purpose trust company in New York specifically to handle USDC issuance. That creates a cleaner organizational structure: one entity issues the stablecoin, another manages the reserves under federal supervision.
Circle wasn’t the only one at the OCC’s door
December 12 was a busy day at the OCC. The regulator didn’t just approve Circle. It also granted a national trust bank charter to Ripple, creating Ripple National Trust Bank. On top of that, the OCC accepted state charter conversions from Paxos, BitGo, and Fidelity Digital Assets.
The timing also aligns with the GENIUS Act, legislation focused on establishing robust oversight frameworks for stablecoins. Circle’s charter approval fits neatly within that legislative vision: federally regulated entities managing stablecoin reserves with clear fiduciary obligations.
The Independent Community Bankers of America and the National Consumer Law Center both filed opposition to Circle’s charter application. Traditional banking groups have long worried that granting bank charters to crypto firms creates competitive imbalances, since these entities can access federal banking infrastructure without bearing the full regulatory burden that comes with deposit-taking.
Why this matters for the broader market
Circle was founded in 2013, and USDC has grown into a cornerstone of crypto market infrastructure. Having its reserves managed by a federally chartered trust bank changes the risk profile for everyone who touches USDC.
Tether, the issuer of USDT and the largest stablecoin by market cap, does not operate under a comparable US federal charter. Circle’s new regulatory posture could become a differentiator as institutional allocators increasingly weigh compliance infrastructure alongside yield and liquidity when choosing which stablecoins to support.
First National Digital Currency Bank’s authority to provide digital asset custody to Circle affiliates opens the door for more sophisticated institutional products, including tokenized treasuries, on-chain collateral management, and structured products that require a regulated custodian in the loop.