Regulatory Record.

The OCC granted Circle final approval to establish First National Digital Currency Bank, N.A., operating as Circle National Trust. The charter places Circle's digital asset custody under direct federal oversight, with management of the USDC Reserve planned as a future capability. Circle applied June 30, 2025 and received conditional approval in December 2025. The trust bank will hold no deposits, make no loans, and will not itself issue stablecoins.

Circle is the first of five conditionally approved firms (Ripple, Paxos, BitGo, and Fidelity are the others) to receive full approval. The signal for the compliance community: federal charters are becoming the standard posture for serious issuers, and the attestation obligations attached to that posture arrive with it. Federal oversight raises the documentation bar. It does not lower it.

A consortium of more than 140 companies announced Open USD (OUSD), a dollar stablecoin governed by an independent entity called Open Standard, led by Bridge co-founder Zach Abrams. Partners span payments (Visa, Mastercard, American Express, Stripe), banking (BBVA, BNY, Standard Chartered), asset management (BlackRock), crypto infrastructure (Coinbase, Solana), and technology platforms (Google, Shopify). Businesses mint and redeem at no cost, and reserve earnings flow to partners after a management fee. Stripe is making OUSD the default stablecoin for its commerce ecosystem. The token is expected to go live later in 2026, launching natively on Solana.

OUSD launches into the GENIUS Act framework, which attaches capital, reserve, attestation, and redemption obligations to a licensed issuing entity. A consortium of this scale still requires the same monthly CPA-attested reserve proof as every other permitted issuer. The larger the network, the more the attestation infrastructure matters.

The Digital Asset Market Clarity Act cleared the Senate Banking Committee by a 15-9 bipartisan vote on May 14, 2026. The bill has passed both the House (294-134, July 2025) and cleared both Senate committees. A merged Senate bill, an ethics provision, and a Senate floor vote are still required before it can reach the President.

The CLARITY Act establishes which agency owns which corner of the crypto market. CFTC receives exclusive jurisdiction over digital commodity spot markets. The SEC retains authority over investment contract assets and digital securities. Payment stablecoins are designated a separate category with joint SEC/CFTC oversight, consistent with the GENIUS Act framework and the March 2026 five-category taxonomy.

The National Credit Union Administration closed the public comment period on its proposed rules governing credit union stablecoin subsidiaries. The NCUA framework creates a pathway for federally insured credit unions to issue stablecoins through chartered subsidiaries, subject to reserve requirements and mandatory monthly CPA attestation.

Credit union stablecoin subsidiaries carry compliance obligations identical to other permitted issuers under the GENIUS Act but often have limited access to the technical infrastructure required for reserve attestation.

The Compliance Bridge LLC filed an Intent-to-Use trademark application in Class 36 (financial services) with the USPTO. No conflict identified with ComplianceBridge Corporation (Class 42 only). Application filed April 12, 2026.

The SEC and CFTC jointly released 68-page interpretive guidance establishing that most crypto assets fall outside securities classification. The guidance introduces a formal five-category taxonomy for all digital assets. Payment stablecoins are defined as their own standalone category, separate from commodities and securities, with joint SEC/CFTC oversight.

This guidance is interpretive. It clarifies existing agency authority. The GENIUS Act remains the governing statute for monthly attestation requirements. The stablecoin category designation reinforces that every permitted payment stablecoin issuer carries the monthly CPA attestation obligation as a condition of legal operation.

The Compliance Bridge LLC was filed with the Colorado Secretary of State on March 17, 2026. EIN 41-4926364. The company was formed specifically to address the reserve reconciliation infrastructure gap created by the GENIUS Act.

The Office of the Comptroller of the Currency published proposed implementing rules for the GENIUS Act's federal licensing track. The rules govern stablecoin issuance by OCC-chartered national banks and their subsidiaries, including reserve composition requirements, custody standards, and attestation obligations.

The OCC rules formalize the requirement that every permitted issuer produce monthly CPA-attested proof that reserves equal or exceed circulation, performed by a qualified independent CPA using documented procedures consistent with AICPA AT-C Section 205.

Paxos Trust Company converted to OCC federal oversight in December 2025, making PayPal USD (PYUSD) the largest dollar-backed stablecoin issued by a federally regulated entity as of 2026. PYUSD reserves are held 100% in US dollar deposits, US Treasuries, and cash equivalents under OCC supervision. Monthly attestation reports are published by an independent accounting firm and are publicly available.

Paxos publishes monthly reserve reports across its issued assets including PYUSD, USDG, and USDP. The PYUSD structure uses segregated, bankruptcy-remote accounts: reserve assets are held as customer property and would not be used to satisfy Paxos corporate debts in an insolvency event.

Following GENIUS Act passage, JPMorgan and other major US banks are actively scaling internal stablecoin and tokenized deposit infrastructure. The GENIUS Act created a pathway for bank-issued stablecoins alongside non-bank issuers, and institutions with existing balance sheet infrastructure are moving to build within that framework.

The practical effect for the compliance community: the issuer population is expanding. Community banks, credit unions, and bank subsidiaries that previously had no stablecoin program now have a defined regulatory pathway. The attestation requirement applies equally to bank-issued and non-bank-issued permitted payment stablecoins.

Circle Internet Financial listed on the NYSE on June 5, 2025 under ticker CRCL, raising approximately $1.1 billion. As of 2026, USDC has over $78 billion in circulation and is natively issued on more than 20 blockchains. Circle publishes monthly reserve attestations performed by Deloitte and Touche LLP under AICPA AT-C Section 205 examination engagements. These reports are point-in-time, focused on the reserve assertion, and are not full audits.

Circle's monthly Deloitte attestation is the established benchmark for what reserve compliance looks like at institutional scale. It is the output format TCB is designed to help other issuers reach. Circle subsequently pursued a national trust bank charter, receiving final OCC approval in July 2026.

President Trump signed the Guiding and Establishing National Innovation for US Stablecoins Act into law on July 18, 2025, following bipartisan passage in the House (308-122, July 17) and Senate (68-30, June 17). The GENIUS Act is the first federal law to define who may issue a stablecoin, how it must be backed, and which regulator must oversee it.

The law explicitly excludes permitted payment stablecoins from the definition of "security" under federal securities law and from the definition of "commodity" under the Commodity Exchange Act. Payment stablecoins enter a standalone regulatory framework, separate from both. SEC and CFTC have no jurisdiction over permitted payment stablecoin issuers under this law.

Every permitted issuer must maintain 1:1 reserves in cash, deposits at insured institutions, or short-term US Treasuries, and must produce monthly CPA-attested proof that reserves equal or exceed circulation. This attestation is a condition of legal operation. Compliance date: the earlier of January 18, 2027 or 120 days after final regulations are published. Final regulations are due from OCC, FDIC, Federal Reserve, and NCUA by July 18, 2026.

The Federal Deposit Insurance Corporation published proposed implementing rules for GENIUS Act compliance by FDIC-supervised state-chartered banks and their stablecoin subsidiaries. The rules establish reserve requirements, permissible reserve asset categories, and monthly attestation obligations consistent with the federal framework.

Total stablecoin market capitalization reached approximately $312 billion in 2025, with USDC alone recording $11.9 trillion in annual transaction volume. The OCC projected market capitalization reaching $500 billion as the GENIUS Act framework takes effect and institutional adoption increases. Analysts project total addressable market reaching $1.9 trillion by 2030.

The majority of issuers outside Circle and Paxos have no equivalent reserve attestation infrastructure. The compliance gap is structural, not technical.

A 2026 Sumsub compliance report found that only 23% of cryptocurrency companies reported full compliance with Travel Rule requirements. The finding reflects a broad pattern of compliance infrastructure gaps across the digital asset industry. The same pattern the GENIUS Act attestation requirement will force issuers to address.

Agreed-upon procedures engagements under AICPA AT-C Section 205 require the CPA to perform specific, documented procedures defined in advance and to report factual findings without providing an opinion. For stablecoin reserve attestation, the procedures are: verify the Closing On-Chain Supply figure, verify the Fiat Reserve Balance from documentation, compare them.

AICPA AT-C Section 205 is the appropriate framework because it allows precise, verifiable procedures without requiring a full financial statement audit. Every TCB deliverable is formatted to the procedures contemplated by this standard. Circle's monthly Deloitte reports are performed under this same standard. The standard was not written for stablecoins. It fits the verification task.