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OCC Record Still Lists Ripple Trust Bank Charter as Preliminary Conditional Approval

The decision letter bars the bank from opening before it meets pre-opening requirements and receives final approval.

Updated 2 min read
Pedestrians pass the Constitution Center, home to the OCC, in Washington, D.C. / TokenPost.ai
Pedestrians pass the Constitution Center, home to the OCC, in Washington, D.C. / TokenPost.ai

As of Oct. 27, 2026, the Office of the Comptroller of the Currency (OCC) lists Ripple National Trust Bank’s charter action as preliminary conditional approval; the bank cannot open before final approval.

CoinGape reported that Ripple had secured final OCC approval and that Ripple CEO Brad Garlinghouse announced the decision. The OCC index continues to show preliminary conditional approval, and the reported Garlinghouse announcement is unverified; Ripple’s Dec. 12, 2025, statement described the action as conditional.

The OCC’s decision letter says the proposed bank may not start business until it satisfies all pre-opening conditions and receives final approval. Stephen A. Lybarger, senior deputy comptroller, wrote that the OCC had granted “preliminary conditional approval only.”

The OCC said it conditionally approved five national trust bank charter applications on Dec. 12, 2025. Institutions that meet their conditions would join approximately 60 national trust banks the agency supervised at the time. The decision letter records nine comment letters, including four from bank trade groups and one from a bank. Several commenters challenged the OCC’s authority and whether the proposed work was consistent with prior national trust bank practice. The agency found the activities permissible.

The proposed bank would manage liquid assets backing Ripple USD (RLUSD), act as collateral trustee for RLUSD holders and provide fiduciary cryptocurrency custody to institutional customers affiliated and unaffiliated with Ripple. The OCC letter says the bank did not then plan to issue stablecoins. Ripple said OCC oversight of RLUSD reserves would complement oversight by the New York Department of Financial Services (NYDFS) and could strengthen holder protections.

The approval requires at least $11.7 million in Tier 1 capital. The bank must hold eligible liquid assets worth at least the greater of 50% of Tier 1 capital or $5.85 million, and maintain eligible liquid assets equal to 180 days of operating expenses.

The approval expires if the bank does not raise capital within 12 months of Dec. 12, 2025, or open within 18 months. The deadlines are Dec. 12, 2026, and June 12, 2027, respectively. The OCC letter does not schedule a final decision date.

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