Ripple’s bid for an OCC national trust bank charter would put RLUSD inside the U.S. banking perimeter and force a question for XRP.
According to the application published by the Office of the Comptroller of the Currency, Ripple proposes “Ripple National Trust Bank,” a de novo national trust bank wholly owned by Ripple Labs and headquartered in New York, to support digital-asset activities, including issuance and custody of RLUSD.
RLUSD is already live on XRPL and Ethereum and is now embedded in Ripple’s payments stack. RLUSD launched in December 2024 and was integrated into Ripple Payments in April, with the company stating it had neared a $250 million market capitalization at that time.
Fresh tracking shows RLUSD’s outstanding supply around $730 million in mid-September, placing it within the top tier of dollar-tokens by float.
A federal charter would sit alongside new U.S. laws governing payment stablecoins. The GENIUS Act, signed in July, defines who may issue payment stablecoins, sets reserve and redemption requirements, and bars permitted issuers from paying yield or interest to coin holders.
The law creates pathways for “federal qualified” issuers, including uninsured national banks chartered by the OCC, and for state-qualified issuers under a capped regime.
Whether a charter would reposition XRP depends on what follows
If Ripple also secured a Federal Reserve master account, RLUSD reserves could be held directly at a Reserve Bank, and settlement could route through Fed services.
The Federal Reserve’s Account Access Guidelines make clear that Reserve Banks apply a tiered, risk-based review and maintain discretion over access, a point reinforced by federal court proceedings in the Custodia litigation. These precedents imply that even chartered institutions face a separate hurdle for master-account access.
The near-term operating picture is straightforward. RLUSD already clears on public rails and is being used inside Ripple Payments with named customers.
If an OCC charter arrives, RLUSD issuance could migrate under the bank umbrella, aligning the product with the federal framework while keeping the token live on XRPL and Ethereum. That is not merely a theoretical shift. The OCC has chartered crypto-native national trust banks before, and public commenters are already weighing in on Ripple’s application.
The XRP question breaks into mechanics.
On XRPL, every transaction consumes a small fee paid in XRP that is destroyed, and every account must post a base reserve in XRP. Reserves were reduced in late 2024 to 1 XRP per account with a 0.2 XRP incremental reserve per object, lowering the balance sheet friction for new users and apps, per XRPL.
The base transaction fee remains 10 drops, or 0.00001 XRP, which means one million transactions burn about 10 XRP, according to the XRPL Transaction Cost documentation. At RLUSD’s current size, fee burns are a weak driver of XRP float, but a charter that pushes RLUSD activity on XRPL higher would widen the flow of market-making and AMM interactions where XRP often serves as base inventory or a routing asset.
Market structure will determine whether RLUSD sidelines or energizes XRP. If enterprise payment flows settle in RLUSD end-to-end, some volumes that previously relied on XRP as a bridge asset could track the dollar token instead, especially for corridors where both origin and destination liquidity is dollar-denominated.
Conversely, deeper RLUSD pools on XRPL give market makers a reason to hold and deploy XRP against RLUSD pairs, collect AMM fees, and support pathfinding across tokenized treasuries and fiat IOUs.
XRPL’s AMM, signaled for mainnet enablement in March 2024, was designed to route through native liquidity, and stablecoin growth tends to amplify that routing, as described in XRPL’s Get Ready for AMM note.
Regulation outside the U.S. adds a second lens for the charter’s value
The EU’s MiCA regime already restricts stablecoin holders’ remuneration and imposes additional obligations as circulation scales, which can favor bank-style issuers.
Hong Kong’s new licensing framework for fiat-referenced stablecoins took effect on August 1, with the HKMA stating it expects to grant the first licenses in early 2026, a timetable that rewards issuers with bank-grade controls.
The Bank of England has proposed holding limits on systemic stablecoins in the UK. An OCC charter would make RLUSD easier to passport into these conversations with large banks and regulated venues.
The litigation overhang remains material but clearer. In August, a federal judge entered final judgment in the SEC case, including a $125 million civil penalty for institutional-sales violations, closing a chapter that had complicated U.S. bank relationships, according to Reuters.
The OCC application states the trust bank would be a wholly owned subsidiary with a dedicated governance layer, a structure that can ring-fence activities and facilitate compliance under the stablecoin law’s issuer definitions.
To frame the trade-offs, the following table outlines three outcome paths and their practical effects on RLUSD and XRP, using current data points and the new law’s contours:
| 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 |
Two numbers anchor the forward view
First, RLUSD’s float has moved into the mid-hundreds of millions, with CryptoSlate data showing about $730 million outstanding.
Second, XRPL’s fee design means even 100 million transactions would burn about 1,000 XRP, a small drain relative to supply, so utility hinges on liquidity breadth and spread capture rather than mechanical burns.
A charter accelerating institutional usage tilts those drivers toward XRPL, where routing makes economic sense, which is where XRP earns its keep.
There is also a corporate build-out to watch. Ripple agreed to acquire Rail and a prime brokerage in Hidden Road to tighten trade finance and distribution around RLUSD and custody, moves that, combined with the OCC filing, point to a bank-grade operating stack.
If the charter lands, the next inflection is not a label change, it is whether RLUSD becomes a preferred settlement asset for regulated venues while XRP remains the native liquidity instrument on XRPL.
The upshot is that a charter would not erase XRP’s role on XRPL; it would formalize the line between a bank-issued dollar token used for settlement and a native asset used for liquidity, pathfinding, and network economics under a law that now defines stablecoin issuance at the federal level.
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