Circle Internet Group has filed an application with the Office of the Comptroller of the Currency (OCC) to form a national trust bank named First National Digital Currency Bank, N.A. If approved, it will supervise Circle’s USDC stablecoin reserves and provide digital asset custody to institutional customers. Leading this effort is CEO Jeremy Allaire, who positions it as part of Circle’s intent to align with emerging U.S. stablecoin regulations, and further bridge its integration into the traditional financial ecosystem.
Strengthening USDC with Federal Oversight
Circle’s proposal for a federally chartered trust bank would allow the company to directly manage USDC reserves under OCC oversight—bringing its operation closer to standard financial practice. These reserves, valued at around $61.9 billion, consist of short-term U.S. Treasuries and cash–currently held at BlackRock and BNY Mellon. The trust structure provides greater transparency by making Circle its own custodian which is an important step in establishing institutional trust.
Aligning with GENIUS Act Requirements
This charter application would meet the expected requirements in the GENIUS Act (Guiding and Establishing National Innovation for U.S. Stablecoins Act), which passed the Senate on June 17 and is pending consideration in the House of Representatives. The new legislation applies generally to stablecoin issuers requiring reserves of liquid and high-quality assets, like U.S. dollars and short-term Treasuries, with required disclosures being timely and periodic. By agreeing to adhere to USDC-specific stipulations before receiving its eventual future regulators charter approval, Circle will mitigate its compliance risk and establish USDC as a regulated stablecoin.
Full-service Offering for Institutions
The yet-to-be-approved trust bank can provide reserve management and custodial services on both equities and bonds, in addition to targeting institutional investors, while providing liquidity services. However, like traditional national trust banks, it won’t accept retail deposits or issue loans. Analysts at Seaport Research highlight this could position Circle as a serious competitor to incumbent players such as BNY Mellon and State Street.
IPO Momentum and Market Response
Circle’s June 5 IPO, which valued the company at roughly $18 billion, saw its stock triple by the close of the session. Since then, shares have surged—some reports indicate increases of over 500%—reflecting heightened market enthusiasm backed by increased regulatory clarity. Institutional analysts from Barclays, Bernstein, and Canaccord have issued “buy” ratings with price targets north of $200, while cautioning on valuation.
Broader Regulatory and Industry Context
This effort unfolds amid a wave of stablecoin-focused initiatives: Circle already secured MiCA-compliant Electronic Money Institution licensing in the EU last year and gained in principle approval in Abu Dhabi earlier this year. The proposed national trust model would offer seamless U.S. operational authority, bypassing the need for numerous state-level licenses. Anchorage Digital is currently the only crypto-native firm with a similar charter.
CEO Perspective and Market Implications
Jeremy Allaire underscores that this isn’t about banking in the traditional sense; it’s a strategic pivot toward trustworthy and scalable infrastructure for internet-era finance. In his words, it “marks a significant milestone in our goal to build an internet financial system that is transparent, efficient and accessible”. The charter would also enhance access to Federal Reserve master accounts—valuable for resilience in the wake of crises like SVB and placing Circle alongside more regulated Tier 2 entities.
Looking Ahead: Approval Timeline and Stakes
OCC applications typically enter a 30-day public comment period before a decision window of up to 120 days. If approved, Circle would solidify its position upon U.S. financial infrastructure, catalyzing institutional adoption of USDC and potentially reshaping the role of stablecoins within dollar-based payment systems.
Conclusion
Circle’s national trust charter request is a cautiously bold step toward integrating the traditional financial infrastructure with the more innovative aspects of crypto. The charter would add more transparency and structure through regulations and the GENIUS Act and possibly lead to new services for institutions. Even with no certainty of approval, the momentum of the IPO and regulatory strategy shows that the company is paving a new road after-and-in spite of-the past months of tumultuousness.
