The collapse of the "intermediaries" era: how five crypto companies turned into federal banks and changed the game

December 2025, the US regulator OCC (Office of the Comptroller of the Currency) made a decision that will overhaul the traditional payment systems architecture. Ripple, Circle, Paxos, BitGo, and Fidelity Digital Assets received federal licenses as national trust banks.

At first glance — this seems like a routine administrative formality. In reality, it means that crypto companies have, for the first time in history, gained the right to apply for direct access to the US Federal Reserve’s payment system (Fedwire). They are no longer peripheral players — now they are part of the core of American financial infrastructure.

Why is this important? Because this step will eliminate the multi-layered system of intermediaries that has been raking in billions in fees for decades. For stablecoin issuers like Circle (USDC) or Ripple (RLUSD), it signifies a revolution in costs.

From “cashier on the periphery” to “system node”: how the modified mechanism works

Previously, any crypto operation in dollars looked like a snake in a gardener’s bed. Circle wanted to transfer 10 million USDC to a client? It had to go through 3-4 commercial banks, each taking its own fee, delay, and risk.

Now, having obtained the status of a federal trust bank and a master account at the Fed, these companies can:

Connect directly to Fedwire — the US federal settlement network. Payments go directly, without intermediaries. No delays. No cascade of fees.

Legally segregate client assets — now it’s not just a company’s promise, but a federal obligation. Fiduciary responsibility means regulators can verify reserves.

Expand functionality — OCC officially allowed them to issue stablecoins, provide custodial services, and tokenize assets in their bank capacity.

Economic effect? According to industry estimates, direct clearing costs for Circle could decrease by 30-50% annually. With an $80 billion USDC reserve circulation, this means savings of hundreds of millions of dollars in fees alone.

Trust bank — not a full-fledged bank, but better

Here, it’s worth dispelling a myth: Ripple and Circle did not receive a “commercial banking license.” They obtained a license for a national trust bank — a specialized instrument.

A trust bank has limitations:

• Cannot accept FDIC-insured deposits
• Cannot issue commercial loans
• Does not expand the money supply through fractional reserve banking

But for crypto companies, this is an ideal structure. USDC is backed 100% by reserves — no need for FDIC insurance, no systemic risk from credit expansion. Instead, the company gains:

Federal regulatory oversight instead of state-by-state licensing (previously, 50 licenses were needed for money transfers).

Fiduciary responsibility — during the FTX scandal, this became critical: asset segregation is now law, not just a promise.

Direct access to the payment system — this is the main advantage.

When Balt found gold: how this license was obtained

Three years ago, this license seemed impossible. Biden’s administration was pursuing a “dampening” policy — banks were ordered to sever ties with crypto. The exit of Silvergate Bank, Signature Bank was a signal: crypto is persona non grata in the banking system.

FTX collapsed, the crypto industry complained. Regulators tiptoed cautiously like a diviner on hot coals.

Then Trump came.

In July 2025, he signed the GENIUS Act — the first federal law granting stablecoins a clear legal status. The first in history. The law explicitly allowed “non-bank institutions” to become “qualified issuers of payment stablecoins” under federal supervision.

Stablecoins were no longer “digital vouchers.” They became tools through which the dollar expanded its digital realm. Strategically, this made sense: regulated stablecoins increase demand for US government bonds, strengthening the dollar’s international standing in the cryptographic era.

The federal push for crypto company banks became a logical sequence.

Why Wall Street cheers: the banking caste counterattacks

The OCC decision triggered not quiet applause but a frenzy of rejection. Bank Policy Institute (representatives from JPMorgan, Bank of America, Citibank) issued three warnings:

First — “regulatory arbitrage disguised as a truce.”

Companies received trust licenses but are actually engaged in payments and clearing — core banking operations. However, parent companies (Circle Internet Financial, Ripple Labs) avoid consolidated oversight by the Federal Reserve. If a critical flaw appears in BitGo’s code — regulators won’t see it.

Second — “breaking down the firebreak.”

Tech giants can now own banks. This means social networks and data could become tools to displace traditional banks, without fulfilling obligations to reinvest in communities (CRA).

Third — “systemic risk without insurance.”

Trust banks do not have FDIC insurance. If a stablecoin loses its dollar peg — traditional deposit insurance systems won’t cover it. Panic could grow to resemble 2008.

BPI pressured the OCC to issue licenses but lost. Now the battleground shifts to the level of the master account at the Federal Reserve.

The last barrier: license isn’t everything yet

Here’s a key detail often overlooked: the OCC issued licenses, but that doesn’t mean automatic access to Fedwire.

The Federal Reserve has independent discretion. Previously, Wyoming-based crypto bank Custodia Bank (lost a court case( after being denied a master account.

Between license and actual access to the payment system — a huge gap.

Ripple and Circle await approval for master accounts at the Fed. BPI has already begun pressure, demanding extraordinary requirements: proof that AML systems are no worse than JPMorgan’s, additional guarantees from parent companies.

If the Federal Reserve resists — crypto companies will have licenses on paper but still operate through commercial banks. The “golden plaque” of a national bank will lose much of its value.

The evolution of stablecoins: from “voucher” to “money”

When Circle )USDC( operated as a private company, the stablecoin was more like a “digital voucher from a tech firm.” Security depended on company management and the reliability of banking partners.

Now:

USDC becomes a reserve held in fiduciary systems under federal oversight. It’s not a CBDC, but the combination of “100% reserves + federal oversight + fiduciary responsibility” offers a credit rating higher than most offshore stablecoins.

Settlements become continuous. Ripple ODL )On-Demand Liquidity(, previously limited by bank working hours, now can convert between fiat and on-chain assets 24/7.

Cross-border payments become more reliable. No more risk of “debanking” — when a bank unilaterally ceases service, the entire channel is blocked.

This isn’t just a paper revolution. It means institutional clients can finally bypass multiple layers of intermediaries.

The future: regulatory clash in the details

Licensing isn’t the end. It’s a new start of conflict.

At the state level: New York Department of Financial Services )NYDFS and other state regulators may challenge federal priority. A new constitutional conflict.

In technical details: The GENIUS Act is already in effect, but many technical requirements remain to be defined by regulators. Capital ratios, risk isolation, cybersecurity standards — all will be points of contention.

On consolidation: With banking status, crypto companies can become partners for traditional financiers — or their prey. Banco do Brasil might buy BitGo’s tech system to enhance its capabilities. The landscape could change fundamentally.

Conclusion:

The OCC decision of 2025 is not just a license. It’s a moment when crypto finance is integrated into the physical architecture of the American banking system. The era of intermediaries and peripheral complacency is over. But the ongoing balancing act between innovation, stability, and competition remains the key issue in the future of US financial regulation.