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USDC reserves are currently managed by BlackRock and held by BNY, but Circle’s charter application would allow it to act as custodian of its own reserves instead of institutional clients
A national trust bank charter would allow Circle to operate across state lines without obtaining separate licenses in each state
Circle would not be permitted to conduct traditional banking activities such as making loans or taking cash deposits under a national trust bank charter
Circle said that becoming a national trust bank would help give USD Coin (USDC) compliance under the GENIUS Act, legislation that passed the U.S. Senate in June 2025 to create new guardrails for dollar-backed stablecoins

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