On February 6, the U.S. Commodity Futures Trading Commission (CFTC) issued a revised employee letter, officially adding National Trust Banks to the list of qualified issuers of U.S. dollar stablecoins.
This decision is based on the GENIUS Act, which was pushed for by the Trump administration in 2025. It means that stablecoins are officially transforming from fringe trading tools into official payment tools that are federally regulated and can be used as futures margin.
With regulatory loopholes plugged, the National Trust Bank has officially entered the market.
According to the official CFTC announcement , this revision addresses the omission of federally chartered banks in the guidelines for the end of 2025. After the revision, National Trust Bank will be on the same starting line as private stablecoin issuers such as Circle and Paxos, marking the beginning of the "banking" era for stablecoins.
More importantly, futures brokerages (FCMs) can now accept these bank-issued stablecoins as margin collateral in regulated futures markets, enhancing the availability of stablecoins in regulated derivatives markets.
National Trust Bank Definition
National Trust Banks are trust banks established under U.S. federal law and approved by the Office of the Comptroller of the Currency (OCC). These banks are financial institutions that have obtained federal charters under the National Bank Act, but their business scope is mainly limited to trust and fiduciary services, rather than traditional full-service commercial banking (such as accepting deposits and making loans).
Main business: asset custody, trust management, trustee services, etc. In the cryptocurrency field, some digital asset companies have obtained federal banking licenses through this route; for example, Anchorage Digital is an institution that has obtained a National Trust Bank Charter issued by the OCC.
What are the differences between them and commercial banks?
Although both the National Trust Bank and the National Commercial Bank are regulated by the OCC, their regulatory levels and requirements differ significantly:
The key difference is that most national trust banks are not required to be covered by deposit insurance. This is precisely why national trust banks are particularly attractive to crypto and payments companies, which can operate custody and trust services at the federal level, regulated by a single federal regulatory body (OCC), without having to obtain money transmission licenses from more than 50 states or be subject to deposit insurance and bank holding company laws like national commercial banks.
In short, National Trust Bank has lower regulatory thresholds but still maintains federal-level rigor, representing a "middle ground" between fintech companies that are completely unregulated by banks and full-fledged commercial banks.
The provisions of the GENIUS Act
Under the GENIUS Act framework, stablecoin issuers must meet the following mandatory requirements:
100% Reserve Mechanism: Issuing institutions must hold 100% highly liquid assets, including US dollars, short-term treasury bonds, or government currency securities funds, to ensure that holders can exchange them back for US dollars at a 1:1 ratio at any time, preventing decoupling events from occurring.
Transparency requirements: Issuers must publish a public disclosure report monthly and accept an independent audit of the reserve composition.
Clear asset classification: These "payment stablecoins" are clearly classified as neither securities nor commodities, reducing the uncertainty of law enforcement.
