Circle获批国家信托银行牌照，稳定币发行商是如何一步步变为银行的？

I. Introduction: Circle Receives Approval for National Trust Bank Charter

On July 10, 2026, Circle announced it had received unconditional final approval from the U.S. Office of the Comptroller of the Currency (OCC) to formally establish a National Trust Bank, named the First National Digital Currency Bank, N.A., which will operate under the name Circle National Trust. On the day of the announcement, the stock price of USDC issuer Circle (NYSE: CRCL) surged over 10% in pre-market trading before closing up approximately 5.7%. The finalization of this approval signifies that Circle's flagship product, USDC, and its underlying asset custody infrastructure have been formally integrated into the U.S. federal regulatory system.

Circle chose to apply for a National Trust Bank charter rather than a traditional full-service commercial bank. A National Trust Bank is a special-purpose financial institution whose core business is strictly limited to the fiduciary custody of digital assets and fiat currency. It is specifically responsible for safeguarding client assets in accordance with legally mandated high-security standards, but the law explicitly prohibits it from accepting public demand deposits like a regular commercial bank or using client funds to issue commercial loans.

This non-commercial bank positioning—"no deposits, no loans"—offers significant structural advantages for crypto/stablecoin companies. By not triggering the legal definition of a commercial bank, the National Trust Bank and its parent company are exempt from the Bank Holding Company Act, are not required to pay insurance premiums to the Federal Deposit Insurance Corporation (FDIC), and are not obligated to fulfill social responsibilities like providing credit to low- and moderate-income communities. This means Circle gains a national-level compliance endorsement while avoiding the extremely heavy capital constraints and compliance operating costs of traditional commercial banks.

II. Regulatory Changes Drive a Surge in Applications

The U.S. financial market experienced an unprecedented surge in applications for federal charters from late 2025 into early 2026, and Circle was one of the participants. According to public market information, within a short 83-day window, the OCC received or conditionally approved 11 National Trust Bank charter applications from crypto companies and fintech firms. This number not only exceeds the total of similar applications over many past years but also marks a restructuring of the underlying financial infrastructure. The core policy driver behind this surge was the GENIUS Act (U.S. Stablecoin Act), signed in July 2025. This act established the first comprehensive federal regulatory framework specifically targeting payment stablecoins in the United States.

Under the act, obtaining the qualification of a "Permitted Payment Stablecoin Issuer" (PPSI) is a prerequisite for legally issuing stablecoins. Only institutions that have undergone rigorous federal or state review and obtained this qualification are permitted to issue and manage stablecoins for the public. The act sets two core standards for this qualification:

1. Legal Asset Reserve Requirement. Payment stablecoins must be fully backed at a 1:1 ratio by high-liquidity, low-risk assets. This means that for every $1 of stablecoin issued on a network, the stablecoin company must hold $1 in cash or highly secure short-term U.S. Treasury bonds in a real-world bank account, ensuring users can always redeem their digital assets for fiat currency without loss.

2. Prohibition on Earnings. The act explicitly prohibits issuers from paying any form of interest or earnings to stablecoin holders. This means the law does not allow stablecoins to distribute interest to users like traditional bank deposits or wealth management products. The core purpose is to clearly define stablecoins solely as payment and settlement tools, preventing them from being treated as high-risk investment products.

Beyond meeting the rigid regulatory requirements of the act, drastically reducing compliance costs is another major driving force behind the large-scale "bank-ification" of crypto companies. In the past, the U.S. payments and digital assets industry was subject to a highly fragmented state-level regulatory system. To legally offer stablecoin issuance and asset custody services nationwide, crypto companies typically had to apply for and maintain Money Transmitter Licenses (MTLs) in all 50 states. Applying for licenses state-by-state costs companies millions to tens of millions of dollars annually, not to mention dealing with inconsistent regulatory reviews across different jurisdictions.

The National Trust Bank charter issued by the OCC grants licensed institutions "federal preemption." Because federal law and authority supersede state law, a Web3 company holding a national bank charter gains a nationwide pass, allowing it to cover the entire country with a single, unified federal standard. This exempts it from the majority of duplicate state MTL application requirements, achieving significant cost savings in compliance.

III. The Ultimate Goal: Direct Access to the Underlying Settlement System

If meeting compliance requirements and reducing costs are the immediate considerations for crypto companies applying for a charter, then breaking free from dependence on traditional commercial banks and achieving independence in underlying fund settlement is their long-term strategic goal for moving toward "bank-ification."

Under the current financial structure, the vast majority of crypto companies themselves are not qualified for direct access to the nation's underlying financial network. They must rely on traditional commercial banks as intermediaries to hold billions or even tens of billions of dollars in stablecoin cash reserves. This model, highly dependent on third-party depository institutions, exposes crypto companies to significant "single point of failure risk." In simple terms, if a crypto company holds all its cash reserves with a few traditional commercial banks, and those partner banks face a liquidity run or declare bankruptcy, the crypto company's funds would be immediately frozen, paralyzing its own operations.

The collapse of Silicon Valley Bank (SVB) in March 2023 fully exposed this systemic vulnerability. At that time, Circle had over $3.3 billion in reserves held at SVB. The bank's sudden run and subsequent takeover by regulators temporarily restricted these funds, directly triggering price volatility for USDC in the secondary market. By becoming a federally regulated National Trust Bank, Circle can internalize the custody and management of its underlying assets, effectively cutting off this contagion risk from external traditional banks.

More importantly, obtaining a federal-level bank charter provides Web3 companies with a potential path to directly connect to the Federal Reserve's payment system. According to relevant U.S. financial regulations, institutions with a federal bank charter are legally eligible to apply for a Master Account or a novel payment account with the U.S. central bank (the Federal Reserve). With such an account, an institution can directly participate in national-level funds clearing, effectively gaining a direct channel to the highest-level government treasury.

If a crypto company were approved to access the Fed's underlying payment system (such as Fedwire or FedNow), it would bring tremendous "settlement disintermediation" advantages. Simply put, in the past, when users exchanged or transferred fiat currency and digital assets, transactions had to go through layers of review by multiple intermediary correspondent banks, with fees deducted at each step. In the future, a licensed Web3 company could complete clearing in one step directly within the central bank's system. This could drastically shorten cross-border settlement times and eliminate the massive costs of intermediaries, fundamentally changing the efficiency of exchanging digital assets for fiat currency.