The focus of this matter is not 'another piece of good news', but rather that stablecoins are being placed on the table for the first time in a way that is closer to the federal banking system.


Circle (the issuer of USDC) has received conditional approval from the U.S. OCC (Office of the Comptroller of the Currency) for its national trust bank charter—this means that Circle is no longer just a 'compliant fintech company', but is moving towards the direction of a federal-level trust bank/custodial bank.



Many people will simply understand it as 'the birth of stablecoin banks'. A more accurate statement is:


Circle is migrating key aspects of USDC (especially reserve asset management and custody) into a federal regulatory framework, making USDC more like a 'dollar settlement tool' that can be directly accessed by the traditional financial system.






1) What role does OCC actually play?




OCC is one of the bank regulatory agencies within the U.S. Department of the Treasury, with core functions including approving/regulating national banks and related institutions, including issuing licenses, setting compliance requirements, and continuously reviewing capital and risk control. Reaching this point with OCC essentially means entering the 'federal rules' track rather than remaining at the level of 'state licenses / ordinary company compliance'.



But it is also important to note: this time it is a license in the direction of the national trust bank, which is characterized by being able to perform trust, custody, asset management, and other businesses, but is typically not equivalent to traditional commercial banks (e.g., it cannot accept deposits or issue loans like commercial banks, nor is it equivalent to FDIC deposit insurance).






2) The direct changes for Circle: from 'borrowing someone else's channel' to 'having a seat in the system'




The past structure looked more like:


The safety narrative of USDC largely relies on 'where the reserves are held, who holds them, and what happens if the custody bank has issues'. Once a black swan appears in the custody chain, the market will worry about liquidity, freezing risk, and short-term decoupling sentiment.



The current direction of change is:


Circle attempts to further embed 'reserve management' and 'custody' within the federal regulatory framework, making itself a more standardized, auditable compliance node, reducing reliance on third-party chains and interpretation costs.






3) The significance of USDC: moving from 'company-issued compliant stablecoin' to 'more like an institutionalized digital dollar channel'




Many people understand USDC as a 'more compliant stablecoin', but what institutions really care about is not the slogan, but:




  • Is the regulatory framework clear?


  • Is the responsible entity traceable?


  • Can the reserve and custody mechanisms be continuously audited and regulated?




As Circle moves towards the national trust bank structure, the narrative of USDC will be closer to 'compliance infrastructure', rather than just 'a relatively normative private stablecoin project'.






4) What might happen next: the threshold of 'can institutions use it' is lowered




In the past, many pension funds, insurance capital, and traditional asset management would be stuck on the issue of 'whether it is compliant to rely on a technology company for funds/settlement' even if they wanted to use stablecoins.


If Circle ultimately meets all OCC requirements and officially begins operations, the 'availability' of USDC will significantly improve for many participants that require strong compliance endorsement: the resistance for scenarios such as settlement, clearing, collateral, and margin management will be lower.






5) USDC vs USDT: this time what has widened is not the 'reputation', but the 'regulatory path'




The market has consistently compared USDC and USDT together, but they are following two different paths:



  • USDC emphasizes regulatory access and normalization within the United States / major jurisdictions


  • USDT leans towards offshore structures and global circulation efficiency




Recently, in the S&P stablecoin assessment system, USDC was rated at a stronger level (e.g., '2/strong'), while USDT was downgraded to a weaker level in November 2025 (related reports quote S&P's adjustment). Such signals are more sensitive to funds that 'must be compliant'.



To put it more straightforwardly:


Compliance funding is not about 'like or dislike', but about 'can it be used'. When there is a difference in regulatory clarity and institutional capability, long-term share changes often exhibit inertia.

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