Wise Resubmits US Trust Bank Application Under GENIUS Act Framework

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Key Takeaways
  • Wise resubmits U.S. national trust bank charter application under GENIUS Act framework after OCC denial on July 21.
  • Federal Reserve halted master account grants while developing limited "payment account" policies proposed in May 2026.
  • OCC granted conditional approvals to crypto-affiliated firms including BitGo, Circle, Fidelity, Paxos and Ripple since December.

Wise plans to resubmit its U.S. national trust bank charter application under the GENIUS Act framework, according to a William Blair note on Friday. The Office of the Comptroller of the Currency denied Wise's original application in a July 21 letter, citing incompatibility with new Federal Reserve policies on payment system Master Account access. The OCC has reshaped its regulatory approach during President Donald Trump's second term, granting conditional approvals to multiple crypto-affiliated banking charter applicants since last December.

OCC Cites Federal Reserve Master Account Policy Incompatibility

The OCC said Wise's application was incompatible with new Federal Reserve policies regarding payment system Master Account access. William Blair analysts Cristopher Kennedy and Marc Feldman wrote that the Fed has essentially halted the granting of master accounts as it develops policies for "payment accounts" that were formally proposed in May 2026. Wise's initial plan relied on having a Fed Master Account, which was made non-viable by the Fed's formal proposal for limited "payment accounts" that included a temporary pause on Tier-3 access requests by uninsured, non-federally supervised entities.

OCC Grants Conditional Approvals to Multiple Crypto Firms Since December

Last December, the OCC granted conditional approvals to banking charter applicants including entities affiliated with BitGo, Circle, Fidelity, Paxos and Ripple, which intend to provide stablecoin services. That same month, BitGo was granted full approval to convert its state trust company into a federally regulated entity. Since then, Crypto.com, Coinbase and Nomura-backed Laser Digital National Trust Bank have received conditional approval, while Sony Bank subsidiary Connectia was approved. Upstart received conditional approval for Upstart Bank, which is focused more on AI than digital assets. Circle won official charter status earlier this month, joining BitGo and Anchorage Digital, which had for years been the only crypto firm holding a national trust charter, granted in 2021. The Federal Reserve Bank of Kansas City approved a limited-purpose "master account" for Wyoming-chartered bank Kraken Financial in March, making it the first crypto firm with direct access to Fed payment rails like Fedwire.

Wise References GENIUS Act Framework and July 2025 Compliance Order

The GENIUS Act passed in the summer of 2025, offering set rules for so-called "payment stablecoins," or assets designed to keep a peg to the U.S. dollar by keeping safe reserves like cash or Treasuries in custody. Reuters reported that Wise's denial addressed specific historical compliance concerns, including a July 2025 multi-state consent order over anti-money laundering risk management issues that Wise says it has since strengthened. Wise said its infrastructure is built to interoperate with both blockchain and traditional payment rails, though the firm remains agnostic on stablecoins, Reuters reported. William Blair said, "Although Wise plans to submit a new application under a Genius Act framework, we do not anticipate a major shift in the company's stance on stablecoins --- Wise is focused on lowering the cost of cross-border transactions, agnostic of the rail."

William Blair Reiterates Outperform Rating with $19 Price Target

William Blair reiterated its Outperform rating on WISE, saying its discounted cash flow (DCF) "implies at least a $19 stock price."

FAQ

Why did the OCC deny Wise's original national trust bank charter application?

The OCC denied Wise's application in a July 21 letter, stating it was incompatible with new Federal Reserve policies regarding payment system Master Account access.

What is the GENIUS Act framework that Wise plans to use for its resubmission?

The GENIUS Act passed in the summer of 2025, offering set rules for "payment stablecoins" — assets designed to maintain a peg to the U.S. dollar by keeping safe reserves like cash or Treasuries in custody.

Which crypto firms have received OCC banking charter approvals since December?

Since last December, the OCC granted conditional approvals to entities affiliated with BitGo, Circle, Fidelity, Paxos, Ripple, Crypto.com, Coinbase, and Laser Digital National Trust Bank, while BitGo and Circle received full approval.

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