Ripple’s application for a national trust bank charter from the Office of the Comptroller of the Currency (OCC) could bring its RLUSD stablecoin under greater U.S. regulatory oversight, potentially influencing the role of XRP.
The proposal, submitted to the Office of the Comptroller of the Currency, outlines the creation of “Ripple National Trust Bank,” a new national trust bank fully owned by Ripple Labs and based in New York. This bank would focus on digital asset activities, specifically the issuing and secure storage (custody) of RLUSD.
RLUSD is currently active on both the XRPL and Ethereum networks and is integrated into Ripple’s payment system. The stablecoin debuted in December of 2024 and was incorporated into Ripple Payments in April. At that point, Ripple reported its market value was approaching $250 million.
Recent data indicates RLUSD’s circulating supply stood at approximately $730 million as of mid-September, placing it among the leading dollar-backed tokens.
This federal charter application arrives alongside evolving U.S. regulations for payment stablecoins. The GENIUS Act, enacted in July, establishes criteria for who can issue payment stablecoins, sets requirements for reserve assets and redemption processes, and prohibits authorized issuers from offering yield or interest to stablecoin holders.
The legislation creates two pathways for issuers: “federally qualified” issuers, including uninsured national banks approved by the OCC, and state-qualified issuers operating under specific limits.
The Impact on XRP Hinges on Future Developments
If Ripple also obtains a master account from the Federal Reserve, RLUSD’s reserve assets could be held directly at a Federal Reserve Bank, allowing for settlement through Federal Reserve services.
The Federal Reserve’s Account Access Guidelines emphasize that Reserve Banks use a tiered, risk-assessed approach to evaluate applications and retain discretion over access, as demonstrated in court proceedings related to the Custodia litigation. This suggests that even chartered institutions face an additional challenge to gain master account access.
In the immediate future, RLUSD operates on public blockchains and is utilized within Ripple Payments with existing clients.
If the OCC grants the charter, RLUSD issuance might be managed under the bank’s structure, aligning the product with federal regulations while maintaining its presence on XRPL and Ethereum. This isn’t just a hypothetical possibility; the OCC has previously chartered crypto-focused national trust banks, and public commentary on Ripple’s application is already underway.
XRP’s Role: A Matter of Mechanics
On the XRPL network, each transaction incurs a small fee paid in XRP, which is then destroyed (burned). Additionally, every account must maintain a minimum XRP balance. In late 2024, these reserve requirements were lowered to 1 XRP per account, plus an additional 0.2 XRP per object, reducing the financial burden for new users and applications, according to XRPL.
The basic transaction fee remains 10 drops (0.00001 XRP), meaning approximately 10 XRP are burned for every million transactions, as outlined in XRPL’s Transaction Cost documentation. Given RLUSD’s current scale, these fee burns have a limited impact on XRP’s total supply. However, an OCC charter that increases RLUSD activity on XRPL could expand market-making and Automated Market Maker (AMM) interactions, where XRP is often used as a base currency or routing asset.
Market dynamics will determine whether RLUSD complements or diminishes XRP’s role. If enterprise payment flows are settled entirely in RLUSD, certain volumes that previously relied on XRP as a bridging asset might shift to the dollar-backed token, especially in corridors where both originating and receiving liquidity is in U.S. dollars.
Conversely, larger RLUSD liquidity pools on XRPL would incentivize market makers to hold and utilize XRP against RLUSD pairs, earning AMM fees and supporting routing across tokenized assets and fiat currencies.
XRPL’s AMM, slated for mainnet activation in March 2024, is designed to route through native liquidity, and stablecoin growth typically amplifies this routing process, as described in XRPL’s Get Ready for AMM announcement.
International Regulations Add Another Perspective
The EU’s MiCA regulatory framework already limits remuneration for stablecoin holders and imposes additional obligations as circulation grows, which may favor issuers operating like banks.
Hong Kong’s new licensing framework for fiat-referenced stablecoins took effect on August 1, with the Hong Kong Monetary Authority (HKMA) anticipating the first licenses will be issued in early 2026, potentially benefiting issuers with robust bank-like controls.
The Bank of England has suggested holding limits on systemic stablecoins in the UK. An OCC charter could make RLUSD more easily integrated into discussions with major banks and regulated platforms in these regions.
Legal uncertainties remain a factor, but with increased clarity. In August, a federal judge issued a final judgment in the SEC case, including a $125 million civil penalty for violations related to institutional sales, resolving an issue that had complicated U.S. banking relationships, according to Reuters.
Ripple’s OCC application states the proposed trust bank would operate as a fully owned subsidiary with its own governance structure, allowing for independent management and compliance with stablecoin regulations.
The following table summarizes possible scenarios and their implications for RLUSD and XRP, considering current data and the new regulatory landscape:
| Outcome | Stablecoin issuer status | Operational effects | RLUSD scale markers | XRP impact channels |
|---|---|---|---|---|
| OCC charter plus Fed master account | Federal qualified issuer under GENIUS (uninsured national trust bank) | Reserve custody at Fed services, direct access to Fed payments subject to Fed review | Faster onboarding of banks and PSPs, higher share of institutional flows on XRPL and Ethereum | More RLUSD-XRP AMM depth, pathfinding through XRP on XRPL, fee burn still minor per-tx |
| OCC charter, no master account | Federal qualified issuer with reserves at supervised banks | Bank-grade compliance uplift without Fed account, easier alignment with MiCA and HK regimes | Growth track continues from ~$730 million float with banking-grade integrations | Liquidity pairs expand on XRPL, XRP used for inventory and routing where efficient |
| No charter | State-qualified via NYDFS trust, subject to GENIUS transition caps | Status quo with partner banks and custodians, more fragmented onboarding | Scale depends on exchange coverage and payments usage | XRP role unchanged from current flows, limited structural tailwinds |
Key Numbers to Watch
Firstly, RLUSD’s circulating supply has reached several hundred million, with CryptoSlate data reporting around $730 million in circulation.
Secondly, XRPL’s fee structure means that even 100 million transactions would only burn approximately 1,000 XRP, representing a minor reduction in total supply. Therefore, utility depends more on the breadth of liquidity and spread capture than on transaction-based burns.
An OCC charter, by accelerating institutional adoption, shifts these factors towards XRPL, where routing is economically viable, which is where XRP adds value.
Corporate developments are also noteworthy. Ripple’s planned acquisition of Rail and a prime brokerage firm, Hidden Road, is designed to enhance trade finance and distribution capabilities for RLUSD and custody services. These actions, combined with the OCC application, suggest the development of a robust, bank-grade operational structure.
If the charter is granted, the next significant development is whether RLUSD becomes a preferred settlement asset for regulated venues, while XRP remains the primary liquidity instrument on XRPL.
In summary, a charter would not eliminate XRP’s role on XRPL; instead, it would clarify the distinction between a bank-issued dollar token used for settlement and a native asset used for liquidity provision, routing, and network economics under a regulatory framework that now defines stablecoin issuance at the federal level.