Recent positive regulatory updates from the US SEC and OCC—what is the impact of policy developments?

Written by: Deng Tong, Golden Finance

On December 11, 2025, the Depository Trust Company (DTC) received a no-action letter from the U.S. Securities and Exchange Commission (SEC), permitting it to tokenize certain custodial assets. DTC aims to leverage blockchain technology to connect traditional finance (TradFi) and decentralized finance (DeFi), thereby building a more resilient, inclusive, and efficient global financial system. Previously, the Office of the Comptroller of the Currency (OCC) issued Interpretive Letter 1188, confirming that national banks may engage in permitted banking activities related to risk-free principal crypto assets.

This article focuses on recent regulatory actions by the U.S. SEC and OCC.

One, SEC: DTCC can tokenize stocks, bonds, and treasuries

Yesterday, the Depository Trust & Clearing Corporation (DTCC) announced that its subsidiary, the Depository Trust Company (DTC), received a no-action letter from the U.S. Securities and Exchange Commission (SEC), authorizing a new service within a controlled production environment under federal securities laws to tokenize real-world assets held by DTC. DTC plans to launch this service in the second half of 2026.

The no-action letter authorizes DTC to provide a three-year tokenization service to DTC participants and their clients on pre-approved blockchains. According to the letter, DTC will be able to tokenize real-world assets, with digital versions enjoying the same rights, investor protections, and ownership as traditional assets. Additionally, DTC will offer a high level of resilience, security, and robustness comparable to traditional markets.

This authorization applies to a range of highly liquid assets, including the Russell 1000 Index (representing the 1,000 largest U.S. publicly traded companies), ETFs tracking major indices, U.S. Treasury bills, bonds, and notes. The significance of this no-action letter is that it allows DTC to deploy the service more quickly under specific restrictions and statements after the finalization of the service.

The SEC’s no-action letter is a key driver in the company’s broader strategy to promote a secure, transparent, and interoperable digital asset ecosystem that fully harnesses blockchain technology.

Frank Lasala, President and CEO of DTCC, said: “I want to thank the SEC for their trust. Tokenization of securities has the potential to bring transformative benefits such as increased collateral liquidity, new trading models, 24/7 access, and programmable assets, but these can only be realized if market infrastructure is solidly prepared for this new digital era. We’re excited to further empower the industry, our participants, and their clients through this opportunity and to push innovation. We look forward to collaborating with stakeholders across the industry to safely and reliably realize the tokenization of real-world assets, advancing the future of finance for generations to come.”

To support this strategy, DTCC’s tokenization platform will enable DTC participants and their clients to use integrated tokenization services supported by the DTCC ComposerX platform suite. This will allow DTC to create a unified liquidity pool within both TradFi and DeFi ecosystems, fostering a more resilient, inclusive, cost-effective, and efficient financial system.

Under the no-action letter, DTC is authorized to provide limited production environment tokenization services via L1 and L2 providers. DTCC will provide further details on onboarding requirements (including wallet registration) and approval processes for L1 and L2 networks in the coming months.

SEC Chair Atkins pointed out: “On-chain markets will bring higher predictability, transparency, and efficiency for investors. DTC’s participants can now directly transfer tokenized securities into other participants’ registered wallets, with these transactions tracked by DTC’s official records. This marks an important step towards on-chain capital markets. I am pleased to see the benefits this plan can bring to our financial markets and will continue to encourage market participants to innovate and push us toward on-chain settlement. But this is just the beginning. I look forward to the SEC considering providing innovation exemptions, allowing innovators to utilize new technologies and business models to transform our markets onto the blockchain without being hamstrung by cumbersome regulations.”

( Two, OCC: Crypto firms with bank charters treated equally to other financial institutions

On December 8, 2025, OCC Director Jonathan Gould stated: “Crypto companies seeking to obtain a U.S. federal bank charter should be treated equally to other financial institutions.”

So far this year, OCC has received 14 applications to establish new banks, “including some from entities engaged in emerging or digital asset activities,” roughly matching the number of similar applications received over the past four years. “Chartering helps ensure the banking system keeps pace with financial developments and supports modern economic growth. Therefore, organizations involved in digital assets and other emerging technologies should have the opportunity to become federally regulated banks.”

Regulators “almost daily receive letters from existing national banks about their innovative products and services. All of this enhances my confidence in OCC’s ability to regulate new entrants and existing banks fairly and effectively.”

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U.S. Comptroller of the Currency Jonathan Gould spoke at the 2025 Blockchain Association Policy Summit. Source: YouTube

( Three, What are the implications of SEC and OCC policy directions?

With DTC approved to tokenize core assets like stocks, bonds, and ETFs on-chain, real-world assets are being formally integrated into the U.S. federal securities system. This means key asset classes in traditional financial markets will have “native versions” on blockchain, enjoying the full legal rights of traditional assets; OCC explicitly states that institutions engaged in digital asset activities can apply for federal bank charters on equal footing with traditional institutions, marking the first official pathway for the crypto industry into the U.S. banking system; the regulatory trends of SEC and OCC actually reflect the U.S. competition to set global standards in digital finance. As blockchain becomes part of financial infrastructure, the U.S. is adopting a model similar to the internet era: leading global rule-setting through institutional and regulatory frameworks.

Appendix 1: Key points from Gould’s speech:

Among the applications currently submitted to OCC, several concern the establishment of new national trust banks or the conversion of existing banks to national trust banks. This growth indicates healthy market competition, reflects a commitment to innovation, and should encourage us all. The number of applications has returned to normal levels for OCC, consistent with prior experience and practices.

Since the 1970s, OCC has been responsible for issuing charters to national trust banks, a power explicitly granted by Congress to the Federal Reserve Board in 1978. Currently, OCC supervises approximately 60 national trust banks. Some banks and industry groups have expressed concerns about certain pending applications, arguing that approval could violate precedent, as it would permit national trust banks to engage in non-trust custodial activities.

What they fail to recognize is that OCC has allowed national trust banks to engage in non-trust activities for decades. In fact, banning such banks from non-trust activities would threaten the dynamic development of the federal banking system and disrupt over a trillion dollars in traditional business of existing national trust banks.

According to regulations, national trust banks must limit their activities to those within trust operations and related services. Despite recent claims to the contrary, since OCC began issuing charters for national trust banks, non-trust activities—especially custody and safekeeping—have always been fully within their authorized scope.

In reality, most national trust banks are already engaged in these activities, including those subsidiaries or affiliates of full-service insured national or state banks. In Q3 of this year, national trust banks reported managing nearly $2 trillion in non-trust custody or safekeeping assets, about 25% of their total assets.

Therefore, if non-trust custody and safekeeping services are deemed unacceptable for pending applications, a reassessment of the legality of existing, mature national trust bank activities is necessary—disrupting existing financial flows. While some new applicants (especially in digital or fintech sectors) may propose new business lines, custody and safekeeping services conducted electronically have a decades-long history.

For example, most banks, including existing national trust banks, hold corporate and client custody electronically. There is no reason to treat digital assets differently. Moreover, we should not confine banks (including existing national trust banks) to past technologies or business models.

This is akin to moving toward decline. The activities of national trust banks have evolved, as have those of other banks nationwide. State trust companies are also involved in digital asset activities—for instance, several states like New York and South Dakota have authorized their trust companies to offer digital asset-related services, including custody.

Some existing banks and banking associations also express concern about potential unfairness or lack of regulatory capacity to oversee new activities proposed by current applicants. These worries could hinder innovative efforts that better serve bank customers and support local economies.

As I mentioned before, OCC has regulated national trust bank activities for decades, ensuring that trustee and non-trust activities (involving hundreds of millions of dollars in assets) are conducted safely and prudently, in accordance with applicable laws.

OCC has extensive experience supervising a native crypto bank—national trust banks—and receives daily feedback from existing national banks on their innovative products and services. All this reinforces my confidence that the agency can effectively regulate new entrants and existing banks’ new activities in a fair and just manner.

We welcome initiatives from current banking institutions and will ensure that new and old banks are treated fairly and adhere to the same high standards, given similar business activities and risk profiles. The federal banking system has evolved from the telegraph era to the blockchain era and actively embraces new technologies, providing banking products and services from rural areas to urban centers—one of its greatest strengths. Despite reforms over 160 years ago, national banks remain a vital part of the U.S. financial system. This is no coincidence. It is the result of long-standing recognition by Congress and courts that banks can and must adapt and develop new ways to conduct longstanding business. Preventing activities of national banks (including national trust banks) deemed “new” or “different” from large tech market advantages from engaging in reasonably permitted activities would undermine this fundamental premise. This could lead to economic stagnation and have profound impacts on the banking system.

Appendix 2: What recent no-action letters has SEC issued?

A no-action letter (English: No-action Letter) is a formal written document issued by a regulator to an organization or individual who requests guidance, indicating that if the described conduct is carried out as specified, the regulator will not take legal or enforcement action. Its core purpose is to reduce regulatory uncertainty, not to serve as legally binding law.

On September 29, 2025, SEC issued a no-action letter indicating that, for a certain token issued by DoubleZero, based on the described facts, SEC will not recommend enforcement action against that token arrangement. This move is seen as an important signal of regulatory shifts in the crypto market, reflecting an official willingness to make fact-specific rulings on whether certain tokens qualify as securities.

On September 30, 2025, SEC’s Division of Investment Management issued a no-action letter to Simpson Thacher, confirming that under certain conditions, state-chartered trust companies can be treated as qualified custodians under Rule 206)4(-2 (Adviser Act) and as custodians permitted under the Investment Company Act of 1940, and that SEC will not pursue enforcement actions against firms and registered funds under this arrangement. This provides clearer regulatory positioning for traditional asset managers regarding crypto custody and compliance services.