Bank of America said in a report on Monday that crypto policy is moving from discussion to implementation, as the OCC, FDIC, and Federal Reserve begin to outline the regulatory boundaries for stablecoins and tokenized deposits in the United States.
Analysts led by Ebrahim Poonawalla said the recent approvals and proposals mark the beginning of a multi-year transition that could push more real-world assets and payments on-chain.
The OCC’s recent conditional approval of National Trust Bank’s charter for five digital asset companies is a meaningful step toward federal acceptance of stablecoins and cryptocurrency custody, analysts wrote. Analysts say the charter opens the door to digital asset activities within the regulated banking system, if offered as a fiduciary service with strong liquidity, compliance and risk controls.
Analysts say the FDIC is expected to issue a notice of proposed rules this week detailing how it would approve payment stablecoins issued by subsidiaries of banks supervised by the FDIC. These rules, required under the GENIUS Act, must be finalized by July 2026 and take effect by January 2027.
The report also highlighted comments from Federal Reserve officials suggesting they are working with other banking regulators on capital, liquidity, and diversification standards for stablecoin issuers as required by the GENIUS Act. Analysts link this to a broader global push, highlighting the Bank of England’s recent proposals for a regime to govern sterling system stablecoins, including asset holding requirements and exposure caps.
Comparison of tokenized deposits and stablecoins
In terms of market structure, Bank of America highlighted JPMorgan and Singapore-based DBS, saying both companies are exploring an interoperable framework for tokenized value transfer between public and permissioned blockchains.
The effort builds on JPMorgan’s JPMD Tokenized Deposit Initiative and highlights the active debate surrounding whether tokenized deposits are a better alternative to stablecoins, the report said.
Bank of America sees a plausible future in which trading in bonds, stocks, money market funds, and cross-border payments moves on-chain, backed by new rules and institutional-grade infrastructure.
To be prepared, banks will need not only blockchain familiarity, but also a willingness to experiment with tokenized assets and on-chain payments, the report added.
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