December 15th, 2025

Three stablecoin developments bankers should know about

Welcome to the latest edition of The Stablecoin Banker, a periodic newsletter to help the banking community stay on top of the most relevant stories in the stablecoin industry. We highlight top stories that are relevant to banks, with our insights and commentary to draw out the most important conclusions.

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“It is important that we do not confine banks, including current national trust banks, to the technologies or businesses of the past. That’s a recipe for irrelevance.” -Jonathan Gould, Comptroller of the Currency (Dec 8)

In This Issue

• Barbarians at the Gate: Five Trust Charters Approved
• Lead Waits for No One: Acquires Stablecoin Payments Company Loop
• GENIUS Not So Smart: Tokenholders Will Wait in Bankruptcy

Plus, tidbits you may have missed in our Coupon Clippings section.

Trust Charters and the Unbundling of Banking

The OCC conditionally approved five digital asset companies for national trust bank charters on December 12th: Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos. In aggregate, the charters permit the applicants to perform a range of services including asset custody, crypto trading and settlement, staking services, escrow, and stablecoin issuance. Banking trade groups including the Bank Policy Institute and ICBA vigorously opposed the applications, arguing that trust charters are being used as a "backdoor" into banking with lighter regulatory requirements. Comptroller Jonathan Gould dismissed these objections, stating that blocking crypto custody would "undermine the dynamic and evolving nature of the federal banking system" and warning that resistance is "a recipe for irrelevance." [Sources: OCC, American Banker, Axios, OCC (Gould Remarks)]

My Take:

These five approvals are less about crypto companies becoming banks and more about crypto companies becoming fully-regulated institutions that can compete directly with banks.

National trust charters are non-depository—these firms can't take deposits or engage in fractional-reserve lending. But they can issue stablecoins, and will be first in line for GENIUS Act licenses. Stablecoins are increasingly functioning as bank-like stores of value with access to Wire, ACH, and card rails. Therefore, these charters represent another step toward the unbundling of banking: payment services decoupled from lending, enabled by regulatory pathways that didn't exist two years ago.

What comes next matters more. These charters make each company eligible to apply for Fed master accounts. If granted, they could settle payments directly through the Federal Reserve, they won't need correspondent banks for payments. That's a structural threat to a revenue stream banks have long taken for granted. If the Fed allows them to hold unlimited reserves in their Fed accounts, then they won’t need banks for anything.

The odds here are longer - recall the sordid history of narrow banking (The Narrow Bank) and non-depository access (Custodia) - but if it were to come through, we’d effectively get something that other countries have had for years: a federal payments license (see the EMI in Europe for comparison). This would completely unbundle payments from depository banking and fundamentally reshape the banking industry.

Comptroller Gould has made his position unambiguous. In his December 8th remarks, he called bank opposition "myopic" and framed the choice starkly: evolve "from the telegraph to the blockchain" or become irrelevant. Banks fighting this are on the wrong side of history—and will face increased competition on their own turf.

Lead Bank Acquires Loop Crypto: Build, Don't Wait

Loop Crypto, an stablecoin payment processor, announced it is joining Lead Bank. Loop provides API-based stablecoin payment infrastructure serving AI companies, gaming studios, digital infrastructure providers, and marketplace platforms. Lead Bank, recently valued at $1.47 billion, has positioned itself as a "bank of record" for fintechs requiring direct connections to Fedwire, ACH, and RTP—plus stablecoin capabilities. The bank already serves as the financial institution partner for the Visa/Stripe/Bridge stablecoin-linked card platform rolling out across Latin America, and counts Ramp, Affirm, and Stripe among its clients.  [Source: Loop Crypto]

My Take:

Lead Bank already sits at the center of the fiat-stablecoin nexus. It powers Stripe-owned Bridge and banks some of the largest stablecoin-native fintechs. With Loop, Lead gains a stablecoin payment processing engine focused use cases where stablecoins have unique advantages: micropayments for AI and cloud resources, gaming digital assets and stored value, and marketplace pay-in and pay-out.

While stablecoin payment processing has been primarily relevant to the on-chain economy, Lead sees an opportunity to bring the stablecoin and fiat rails closer together. Notably, they aren’t waiting for further regulatory clarity to do it - and neither do banks waiting on the sideline. What banks need is a beachhead—an initial foothold in digital asset services that positions the bank to evolve as the market develops. Lead has been building that beachhead for three years, and just raised at a 7.6x multiple of book.

The Fine Print on GENIUS Act Protection

Bankruptcy expert Professor Adam Levitin has published an analysis showing that under the GENIUS Act, stablecoin holders actually rank fifth in line during an issuer bankruptcy—behind repo lenders, DIP financiers, bankruptcy professionals, and setoff claims. While the legislation gives stablecoin holders priority over general unsecured creditors and excludes reserves from the bankruptcy estate, Levitin argues these protections are undermined by the mechanics of how bankruptcy actually works. The result: stablecoin holders could face significant haircuts and wait months or years for any recovery, a stark contrast to FDIC-insured deposits that typically pay out within days. [Source: Credit Slips]

My Take:

Professor Levitin's analysis is worth reading in full. It's hard to imagine this Congress passing legislation that gets deep into the weeds of bankruptcy mechanics. The GENIUS Act may have been rushed, but the law is now passed, and regulators are building the implementing rules.

I'm optimistic that regulators are closer to these issues than legislators and can address the gap. I'm no bankruptcy expert, but two thoughts come to mind. First, regulators could require stablecoin issuers to pre-contract with a debtor-in-possession lender and a trustee, eliminating the uncertainty around who finances and administers a potential workout. Second, the expected cost of that workout could be included in capital requirements—essentially pre-funding the bankruptcy process so it doesn't consume reserves meant for stablecoin holders. If the costs are known before any failure and already set aside, much of the timing uncertainty Levitin identifies goes away.

For bankers, the takeaway is straightforward: stablecoins are not deposits, and reserve requirements do not equal depositor protection. When customers or boards ask about stablecoin safety, the honest answer is that even well-regulated stablecoins carry issuer credit risk that FDIC-insured deposits do not. Banks that can articulate this distinction clearly—and offer products that preserve actual deposit protections—will find themselves well-positioned as the market matures and counterparty risk becomes better understood.

Coupon Clippings

PNC Embeds Bitcoin Trading in Private Bank Platform

PNC Bank launched direct bitcoin trading for Private Bank clients through its own digital banking platform, powered by Coinbase's Crypto-as-a-Service infrastructure—making it the first major U.S. bank to offer native crypto access rather than pointing clients to external exchanges. The integration lets eligible clients buy, hold, and sell bitcoin within PNC's Portfolio View interface, with Coinbase handling execution and custody behind the scenes. For now, it's limited to high-net-worth clients and bitcoin only, but PNC plans to expand access to additional client segments. The model—bank UX, crypto-native backend—may be the template for how traditional banks enter digital assets without building proprietary infrastructure. [Full Story]

Signet's Successors Return with a "Narrow Bank"

Former Signature Bank executives Scott Shay and Jeffrey Wallis have launched N3XT, a Wyoming SPDI-chartered bank offering 24/7 programmable USD payments built on a private permissioned blockchain—essentially Signet 2.0. Every dollar is backed 1:1 by cash or short-term Treasuries. N3XT targets crypto firms, FX traders, and logistics companies needing round-the-clock settlement: think programmable payments that auto-execute on delivery confirmation, reducing letters of credit and freeing working capital. N3XT doesn’t have Fed access, making it dependent on correspondent banks for fiat payments, which may be fine for its B2B ecosystem play (and this will probably remain for long time since N3XT bills itself as "the first narrow bank in the United States” and is a regulatory sibling to Custodia). For bankers, N3XT is a test case for two questions: Is there real demand for non-FDIC-insured, payments-only banking? And can a full-reserve model that explicitly rejects fractional-reserve lending build a sustainable business? [Full Story]

Sony Bank Plans USD Stablecoin for Global Gaming Ecosystem

Sony Bank plans to launch a USD-pegged stablecoin by fiscal 2026 for payments across PlayStation, streaming, and anime platforms, targeting the 120 million monthly active PlayStation Network users. The company has applied for a U.S. banking charter through its Connectia Trust subsidiary. Predictably, the ICBA has already opposed the application, arguing the trust-charter structure blurs banking-commerce boundaries. On its face, using a stablecoin for in-game purchases and subscriptions solves a problem that doesn't really need solving—plenty of gaming companies run stored-value systems without blockchains. But Sony operates a successful bank in Japan, and a stablecoin could do something more interesting: create a single global stored-value instrument that works across 200+ countries, enables instant creator payouts without cross-border friction, and positions Sony's financial arm as infrastructure rather than just a payments cost center. If Sony connects fiat rails, DeFi yield opportunities, and lending to this stablecoin, they may have found a way into U.S. banking's deposit-like functionality without actually becoming a bank. [Full Story]

DTCC Gets Green Light for Securities Tokenization Pilot

The SEC issued a no-action letter allowing DTCC's depository subsidiary to tokenize certain securities—Russell 1000 stocks, major index ETFs, and Treasuries—starting in late 2026. The pilot enables DTC participants to represent their security entitlements as tokens that can transfer between registered wallets 24/7. However, tokens are excluded from risk calculations and cannot satisfy margin requirements with DTC, and there's no impact on clearing—trade verification, netting, and cash settlement all remain unchanged. It's a far cry from what's needed to enable 24/7 securities trading, but it does let participants experiment with bilateral arrangements, such as using tokens to settle repo and securities lending transactions outside of DTC's core systems. The next bottleneck is the cash leg: DTCC is exploring its own stablecoin, which makes sense given that true instant settlement requires both securities and cash to move at the same speed. I've written before about the opportunity for banks in tokenized securities—liquid securities lending, novel secured credit instruments, and streamlined trading access for customers. We're still a ways from that reality, but the groundwork is being laid. [Full Story]