OCC News Release 2025-125 and the GENIUS Act Issuer Register: Conditional Approvals, Reporting Forms, and Open Rulemaking

On December 12, 2025 — five months after the GENIUS Act was enacted on July 18, 2025 — OCC News Release 2025-125 lists conditional approval of at least five national trust bank charter applications tied to digital asset activities, with Conditional Approval numbers ranging from #1353 to #1358 ¹². The most concrete artifact in the public record is OCC Control Number 2025-Charter-342299, associated with Circle Internet Financial, LLC, 1 Lincoln Street, Suite 31-113, Boston, MA 02111, applying to charter "First National Digital Currency Bank, National Association" under Conditional Approval #1356 ¹². A parallel OCC Bulletin — 2026-24, published June 11, 2026 — establishes two new reporting forms (PS-01 for weekly activity and reserves; PS-02 for quarterly condition and income) that permitted payment stablecoin issuers operating under OCC supervision are indicated to file ³.

The December 2025 Conditional Approvals: What the OCC Record Lists

OCC News Release 2025-125 (December 12, 2025) is the primary public document anchoring the issuer register. The record lists at least three named entities with assigned conditional approval numbers:

• BitGo Trust Company — Conditional Approval #1353 (December 12, 2025), cited in connection with conversion to a national bank. The OCC Interpretations & Decisions registry also lists Corporate Decision #1367 (February 2026) as referencing BitGo's conversion pathway ⁴⁵⁶.
• Paxos Trust Company, National Association (Charter #25379) — Conditional Approval #1358, granted subject to conditions related to the entity's compliance program and, per OCC search metadata, an active enforcement action ⁷⁸.
• Circle Internet Financial, LLC — Conditional Approval #1356, for the de novo charter of "First National Digital Currency Bank, National Association" (OCC Control Number 2025-Charter-342299) ¹².

A fourth entity, Laser Digital National Trust Bank, appears in Corporate Decision #1377 (May 29, 2026) in the OCC Interpretations & Decisions registry as having an approved or pending charter application citing digital asset activities ⁴⁶. Fidelity Digital Asset Services is also listed in OCC search results as among entities with active or pending status under the GENIUS Act framework ⁵.

All five approvals are described as conditional. The record does not indicate that any of these entities had received a final, unconditional charter as of the findings available to this paper.

OCC Interpretive Letter 1183 (issued March 7, 2025 — pre-enactment) is cited in the record as reaffirming national bank authority for stablecoin-related activities, providing a pre-GENIUS Act legal foundation on which trust companies were already operating ⁹⁴.

Pathway Architecture: National Trust Bank Conversion and Charter as Primary Routes

The GENIUS Act (enacted July 18, 2025) creates the category of "permitted payment stablecoin issuer" and, per Federal Reserve Governor Barr's March 31, 2026, remarks, its primary tool for mitigating run risk is limiting issuer activities and providing regulatory clarity ¹⁰¹¹. The Act contemplates at least three authorization pathways — IDI subsidiary, OCC nonbank charter, and state-qualified issuer (≤$10B opt-in) — though the findings available to this paper most directly document the OCC national trust bank pathway.

The OCC Interpretations & Decisions registry now more specifically indicates that the national trust bank conversion (for existing state trust companies converting to national charters, as in BitGo's case) and the national trust bank charter (for de novo applicants, as in Circle's and Laser Digital's cases) are the primary pathways utilized under the GENIUS Act framework as of early-to-mid 2026 ⁶⁴. Corporate Decision #1377 (May 29, 2026) for Laser Digital National Trust Bank is the most recent entry in the registry identified by the current record, extending the timeline of OCC activity under the framework through at least late May 2026 ⁶.

All five December 2025 conditional approvals identified in OCC News Release 2025-125 appear to use the OCC national trust bank charter or conversion pathway. The record does not yet contain a publicly identified entity that has received approval under the state-qualified ≤$10B opt-in pathway or the IDI-subsidiary pathway, though the record is silent on whether applications under those pathways exist in non-public supervisory channels.

OCC Bulletin 2026-3 is cited in the findings as an early 2026 implementation bulletin, though its specific contents are not fully detailed in the records available to this paper ⁹.

Reporting Obligations: PS-01 and PS-02 Forms

OCC Bulletin 2026-24 (published June 11, 2026) is the most operationally specific document in the current record. It establishes two reporting forms for OCC-supervised permitted payment stablecoin issuers:

• PS-01: Weekly activity and reserve reporting.
• PS-02: Quarterly condition and income reporting.

The bulletin identifies OCC internal leads Shaquita Merritt and David Stankiewicz as contacts ³. A 60-day public comment window opened following the bulletin's June 11, 2026, publication date. As of the findings available to this paper, the register of external commenters — law firms, agents, auditors — on these specific forms has not yet been mapped from the public record ³.

Compliance Conditions and Enforcement History: The Paxos Record

Conditional Approval #1358 for Paxos Trust Company, N.A. is the most compliance-laden entry in the current record. OCC records indicate the approval was granted subject to an active enforcement action and conditions related to the entity's compliance program ⁷⁸. Corporate Decision #1365 (February 2026) references public comments citing a "history of enforcement actions against an affiliate" of one of the 2025 charter applicants — a reference the record associates with the Paxos group ⁸. Corporate Decision #1367 (February 2026) separately refers to deficiencies and litigation raised by commenters regarding the planned activities of the group ⁷.

The record does not specify which affiliate is referenced, what the prior enforcement actions concerned, or whether the conditions imposed in Conditional Approval #1358 have been satisfied.

The Rulemaking Clock: CIP Proposal and Pending Agency Rules

A joint agency proposal dated June 18, 2026, initiates rulemaking for "Permitted Payment Stablecoin Issuer Customer Identification Programs" pursuant to the GENIUS Act, with a 60-day comment period following Federal Register publication ¹⁰¹¹. Governor Barr's March 31, 2026, remarks indicate that agency-level details on reserve assets, capital, and liquidity requirements remain pending during the implementation phase — meaning the duties matrix for reserve composition, segregation, and redemption obligations is not yet fully settled in the public record ¹¹.

The conversion filing OCC 2025-Conversion-342828 lists Mark Chorazak (identified in broader public records as a partner at Skadden, Arps) as a representative, providing one named node in the emerging stablecoin compliance professional network ¹².

Pre-Positioning: What the Record Shows and Does Not Show for BitGo

The findings contain a discrepancy regarding BitGo Trust Company. Step 0 of the trail cited OCC filing "nr-occ-2025-125c" as disclosing BitGo's December 12, 2025, national bank conversion application. However, subsequent record searches (Steps 1 and 2) failed to surface that specific document in the OCC's public-facing 2025 news release index, and no secondary reporting independently surfaced it ¹³¹⁴. BitGo's Conditional Approval #1353 does appear in the OCC Interpretations & Decisions index ⁴⁶, and Corporate Decision #1367 (February 2026) is also listed in that registry as referencing BitGo's conversion pathway ⁶ — but the specific filing "nr-occ-2025-125c" remains absent from the publicly accessible record as of this paper's findings.

What the Record Does Not Show

• No final, unconditional charters: All five December 2025 approvals are conditional. The record does not indicate any issuer has received a final charter under the GENIUS Act framework.
• No state-pathway or IDI-subsidiary applicants identified: The public record available to this paper does not name any entity that has applied for or received approval under the state-qualified ≤$10B opt-in or IDI-subsidiary pathways.
• Reserve composition and redemption rules not yet finalized: Governor Barr's March 2026 remarks and the June 2026 CIP proposal both indicate that key duties — reserve asset composition, segregation, redemption obligations — remain in rulemaking and are not yet settled in the public record.
• The specific conditions on each conditional approval are not public: The record indicates conditions exist (especially for Paxos #1358) but does not disclose their full text.
• The Paxos affiliate enforcement history is not specified: Corporate Decisions #1365 and #1367 reference prior enforcement actions and deficiencies but do not name the specific affiliate, the subject matter, or the resolution.
• The external commenter network on PS-01/PS-02 is not yet mapped: The 60-day comment window on OCC Bulletin 2026-24 was open as of the findings; no external filers have been identified in the record.
• BitGo's specific conversion filing (nr-occ-2025-125c) is not publicly accessible: This document was cited in the trail but could not be located in the OCC's public index, though BitGo's Conditional Approval #1353 and Corporate Decision #1367 do appear in the Interpretations & Decisions registry.
• Fidelity Digital Asset Services pathway details: Fidelity appears in OCC search results as having active or pending status, but no conditional approval number or pathway details appear in the records available to this paper.
• Laser Digital National Trust Bank conditions: Corporate Decision #1377 (May 29, 2026) lists Laser Digital in the OCC registry, but the specific conditions, control number, and pathway details of that decision are not yet detailed in the records available to this paper.