• Key insight: The OCC needs to act before banks lose the ability to compete in a market where consumers no longer tolerate below-market-rate returns.
• What’s at stake: Banks and their regulators have a narrow window to reckon with custody modernization.
• Forward look: Banks and their trade groups should engage with the OCC now, rather than react to a standard they had no hand in shaping.
  

The head of crypto at Visa said recently that if he were running crypto at a bank, he would spend 95% of his time on on-chain lending. He’s right to focus there, but the more fundamental issue runs deeper than any single product category. On-chain infrastructure is in the process of making one of banking’s most durable value propositions available outside…