Ripple has outlined the regulatory structure supporting its Ripple USD (RLUSD) stablecoin, distinguishing between different licensing frameworks and their reserve requirements as institutions evaluate the token for payments and settlement operations.
In a September 11 blog post, Ripple explained how stablecoin protections depend on an issuer's license type, capital requirements, and banking oversight. The company stated: "A money transmitter license, a state trust charter, and prudential supervision by a banking regulator all involve government oversight, but they carry different capital requirements, different reserve rules, and different consequences if an issuer fails."
Current RLUSD Structure
RLUSD is issued by Standard Custody & Trust Company, a Ripple subsidiary operating under a New York Department of Financial Services limited-purpose trust charter. The framework includes segregated reserves and independent attestations that examine reserve disclosures. Ripple selected BNY Mellon as the primary reserve custodian in July 2025 and said it would use the bank's transaction banking services.
Federal Approval Still Pending
Ripple received conditional approval in December 2025 to establish Ripple National Trust Bank, which would handle reserves backing the stablecoin on a directed basis and perform collateral trustee services. The company characterized this approval as an intermediate step, with the full federal chartering process still subject to completion.
The Office of the Comptroller of the Currency's approval letter specifies that authorization to begin business depends on satisfying all preopening requirements. Standard Custody would remain the issuer under New York supervision, while the separate federal bank would assume its approved responsibilities.
Ripple was one of five crypto-related trust bank applications the OCC conditionally approved on December 12, 2025, alongside institutions associated with Circle, Bitgo, Fidelity, and Paxos.
Separate Collateral Framework
The Commodity Futures Trading Commission announced a digital assets collateral pilot on December 8, 2025, allowing futures commission merchants to accept qualifying digital assets as margin collateral under specified conditions. Ripple characterized this staff no-action position as conditional relief governing collateral treatment rather than an endorsement of specific stablecoins. Participating firms face reporting and risk-management obligations.
Ripple also identified its prime brokerage business as an early adopter of BNY's tokenized deposit services launched in January, which mirrors participating customers' deposit balances on a private blockchain for collateral and margin workflows.
