Crypto Firms’ Ongoing Push Toward the Banking Perimeter: Chartering Efforts and Regulatory Tension
Executive Summary
- Crypto firms continue the pursuit of national bank and state trust charters to access payment rails, supervisory clarity, and institutional credibility; regulators remain cautious however, due to unresolved concerns around liquidity risk, operational resilience, and the fit of digital-asset activities within prudential frameworks.
- State trust charters have emerged as the most achievable entry point, yet they raise questions about supervisory consistency, regulatory arbitrage, and when trust-charter activities become functionally equivalent to banking, and thus warrant federal oversight.
- The prolonged back-and-forth between applicants and regulators reflects broader policy tensions—innovation versus safety…




