Bank of America: The US banking industry is accelerating towards a multi-year on-chain finance era

A recent research report released by U.S. banks indicates that, against the backdrop of a substantial shift in regulatory attitudes, the U.S. banking industry is entering a multi-year “on-chain” transition phase. As the Office of the Comptroller of the Currency (OCC), Federal Deposit Insurance Corporation (FDIC), and Federal Reserve begin establishing clear regulatory frameworks for stablecoins and tokenized deposits, cryptocurrency policies are moving from discussion to implementation.

Led by analyst Ebrahim Poonawala, the research team stated that a series of recent regulatory approvals and rule proposals signify that the U.S. financial system is laying the institutional groundwork for real-world assets and payments to go on-chain. Recently, the OCC conditionally approved five digital asset companies to obtain national trust bank licenses, which is seen as an important step toward the federal-level formal acceptance of stablecoin issuance and crypto asset custody. These activities must be conducted in the form of trust services and meet strict liquidity, compliance, and risk management requirements.

Meanwhile, the FDIC is expected to issue proposed rules clarifying the approval process for its regulated bank subsidiaries issuing payment stablecoins. These rules are based on the GENIUS Act and are expected to be finalized by mid-2026, with official implementation in early 2027. The report also notes that the Federal Reserve is collaborating with other regulators to develop standards for capital, liquidity, and risk diversification for stablecoin issuers, also stemming from the GENIUS Act.

The U.S. banking sector compares this progress with global trends, mentioning the recent regulatory proposals by the Bank of England regarding systemic pound stablecoins, including asset reserve requirements and risk exposure limits, indicating a convergence among major economies on stablecoin regulation.

At the market structure level, the report highlights the explorations of JPMorgan Chase and Singapore’s DBS Bank, both researching interoperable frameworks for tokenized value transfer between public and permissioned blockchains. This initiative builds on JPMorgan’s JPMD tokenized deposit project and has sparked industry discussions on whether “tokenized deposits are superior to stablecoins.”

The U.S. banking industry believes that, with clearer regulations and mature institutional infrastructure, core financial activities such as bonds, stocks, money market funds, and cross-border payments are likely to gradually migrate on-chain in the future. To respond to this trend, banks need not only to master blockchain technology but also to proactively prepare in the issuance of tokenized assets and on-chain settlement.