If OCC grants banking licenses to Ripple: Will RLUSD replace or promote XRP?

Ripple is seeking a national trust bank charter from the Office of the Comptroller of the Currency in America (OCC), a move that could bring the stablecoin RLUSD under federal banking regulation and raise new questions about the role of XRP.

According to the records submitted to OCC, Ripple proposes the establishment of Ripple National Trust Bank - a new national trust bank, wholly owned by Ripple Labs, headquartered in New York. This bank will support digital asset activities, including the issuance and custody of RLUSD.

RLUSD is now operational on XRPL and Ethereum, and has been integrated into Ripple's payment system since April 2025, after its launch in December 2024. At that time, the market capitalization of RLUSD reached nearly 250 million USD. By mid-September 2025, the circulating supply had increased to approximately 730 million USD, placing RLUSD among the largest stablecoins by circulating supply.

The new legal framework and the role of OCC charter

The federal license from OCC will accompany the GENIUS Act signed last July, the first law in America that clearly defines who is allowed to issue payment stablecoins, requires reserves and buyback processes, while prohibiting interest payments to holders.

The law creates two pathways:

• Federal qualified issuers: include national banks that are not insured and are licensed by the OCC.
• State-qualified issuers: issuers licensed by the state with limited scope.

If Ripple applies for a master account at the Federal Reserve (Fed), the RLUSD reserves could be held directly at the Fed and use the central bank's payment infrastructure. However, the Fed applies a multi-layered risk assessment process and has full discretion, as the Custodia lawsuit has shown.

In the short term, RLUSD is still used on public blockchains and in Ripple Payments with enterprise customers. If approved by the OCC, the issuance of RLUSD will move to the federal banking framework, creating higher legitimacy while still operating on XRPL and Ethereum.

Affects XRP

The question is whether RLUSD will replace or complement the role of XRP:

• On the XRPL, every transaction requires a fee in XRP (burned), and each account must maintain a reserve of XRP. Although this fee is very small (one million transactions only burn about 10 XRP), the increase in RLUSD activity on the XRPL could drive demand for liquidity, AMM, and the role of XRP in routing.
• If the corporate payment line completely shifts to RLUSD, the demand for using XRP as a bridge asset may decrease, especially in the USD-USD corridors.
• Conversely, if RLUSD creates large liquidity pools on XRPL, market makers will be incentivized to hold XRP to trade with RLUSD, earn AMM fees, and support liquidity routing.

XRPL is set to deploy AMM from March 2024, and the growth of stablecoins is likely to deepen this liquidity network.

International perspective

The global legal framework is tightening stablecoins:

• Europe (MiCA): prohibits paying interest to holders of stablecoins, imposes additional supervisory obligations at scale.
• Hong Kong: from 1/8/2025, a fiat-referenced stablecoin licensing regime will be implemented, with the first licenses expected to be granted in early 2026.
• Mr.: The Central Bank proposed to limit the number of stablecoins in the system.

In this context, an OCC charter will help RLUSD easily "passport" to cooperate with major banks and internationally compliant exchanges.

The SEC lawsuit and new banking structure

In August 2025, Ripple settled its lawsuit with the SEC with a fine of 125 million USD for violating the sale of tokens to institutional investors. This event somewhat removes the legal barriers for the relationship between Ripple and American banks.

The OCC filing shows that the trust bank will be a wholly owned subsidiary of Ripple, with its own governance layer, helping to separate operations and comply with the definition of the GENIUS Act.

The main three scenarios

| Scenario | Release Status | Operational Impact | RLUSD Scale | Impact on XRP | | --- | --- | --- | --- | --- | | OCC charter + Fed account | Federal qualified, OCC trust bank | Reserves at Fed, direct connection to FedNow, faster bank payments | Attract institutional cash flow, increase market share on XRPL & Ethereum | Increase AMM depth RLUSD-XRP, expand routing, XRP burn fee remains low | | OCC charter, no Fed account | Federal qualified, reserves at commercial bank | Bank compliance, easy integration with MiCA & Hong Kong | Maintain growth from ~730 million USD | XRPL liquidity expands, XRP still needed for routing | | Not OCC charter | State-qualified via NYDFS | Continue to rely on partner banks | Scale depends on the exchange & payment | Role of XRP remains unchanged, no new breakthroughs |

Conclusion

RLUSD has reached a scale of hundreds of millions USD and has become an important part of the payment system of Ripple. If granted an OCC charter, RLUSD could become a preferred payment asset at financial institutions while XRP continues to play the role of the primary liquidity asset on the XRPL, supporting routing and AMM.

The key point is: an OCC charter will not eliminate the role of XRP, but will formalize the boundary between a stablecoin issued by a bank and a native asset that serves the liquidity and economy of the network.

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