Currently, the national trust bank system may still face legal challenges. The Conference of State Bank Supervisors (CSBS) has publicly stated that the OCC has created a previously non-existent federal banking charter model for digital asset companies by combining various legal authorities, a structural design that could provoke litigation. Meanwhile, some legal scholars have raised more direct questions about the OCC’s approval authority. For instance, policy research from George Washington University suggests that the OCC’s allowance of national trust banks to issue stablecoins and engage in other non-traditional trust activities may exceed the statutory powers granted under the National Bank Act and related federal regulations, and recommends a reevaluation of these approval decisions. Currently, multiple industry organizations, including the Bank Policy Institute (BPI), have publicly stated that they are assessing the possibility of challenging the OCC’s approval decisions through judicial proceedings. If federal courts ultimately determine that the OCC exceeded its statutory authority during the approval process, the relevant national trust bank charters could theoretically be revoked, suspended, or required to undergo reexamination. Although this outcome remains highly uncertain, the legal disputes surrounding the legitimacy of the national trust bank system will remain a critical variable to monitor in the system’s future development. Beyond legal controversies, the national trust bank system also faces issues related to financial stability. Traditional banking institutions generally believe that as the issuance scale of stablecoins continues to expand, the interconnection between the digital asset market and the traditional banking system will deepen, potentially creating new sources of systemic risk. In particular, within the stablecoin sector, some studies argue that their economic function is increasingly resembling that of traditional bank demand deposits. Stablecoin issuers continuously issue digital liabilities redeemable at par value, backed by reserves such as cash and short-term U.S. Treasuries. When market confidence is strong, this model operates stably; however, if negative expectations arise regarding the quality of reserve assets or redemption capacity, large-scale concentrated redemptions could rapidly strain liquidity. In extreme cases, stablecoin issuers may need to quickly sell large volumes of short-term Treasuries or withdraw cash reserves held at cooperating commercial banks to meet redemption demands. This means that a liquidity shock in the stablecoin market could extend beyond the digital asset sector itself, transmitting pressure to the Treasury market and the traditional banking system, thereby generating cross-market liquidity stress. This content is excerpted from Web3Caff Research’s report: “U.S. Crypto Banking System Special Report (Part 2): Circle Secures a Bank Charter—Why Are Web3 Companies Universally Moving Toward ‘Banking’? A Comprehensive Analysis of Their Charter Attributes, Approval Context, Driving Factors, Industry Impact, and Future Trends.” View the full report here👇 https://t.co/AYq5DPWwDq