Key Takeaways
- • The OCC's Interpretive Letter 1183 (March 7, 2025) and the FDIC's March 28, 2025 action let national and FDIC-supervised banks engage in permissible crypto activities without prior supervisory non-objection.
- • The Federal Reserve Board withdrew its April 24, 2025 guidance that had required state member banks to notify it in advance of crypto activities.
- • The GENIUS Act, signed July 18, 2025, created the first federal framework for payment stablecoins, requiring one-for-one reserve backing and allowing insured-bank subsidiaries to apply to issue them.
- • Binance Research estimated institutions held about 3.88 million BTC in May 2026, or 18.5% of Bitcoin's 21 million maximum supply, with ETFs holding about 1.32 million BTC and public companies about 1.24 million BTC.
- • Since the SEC approved U.S. spot bitcoin ETFs in January 2024, investors can hold bitcoin exposure through ordinary brokerage and retirement accounts, with custodians holding the underlying coins.
Summary
According to a Pew Research Center survey conducted in February 2024 of 10,133 adults, 17% of U.S. adults say they have at some point invested in, traded, or used cryptocurrency, while 63% express little or no confidence that available methods for doing so are reliable and safe. Banks are adapting to this combination of participation and distrust, often by offering crypto exposure through familiar channels rather than requiring customers to manage private keys or blockchain transactions.
The most significant driver of bank engagement has been a shift in federal regulatory posture. On March 7, 2025, the Office of the Comptroller of the Currency said in Interpretive Letter 1183 that national banks may provide crypto-asset custody, engage in certain stablecoin activities and participate in blockchain networks without first obtaining supervisory non-objection. The FDIC followed on March 28, 2025, telling the banks it supervises that they could engage in permissible crypto activities without prior approval. Acting FDIC Chairman Travis Hill said at the time, "With today's action, the FDIC is turning the page on the flawed approach of the past three years." On April 24, 2025, the Federal Reserve Board withdrew its earlier guidance requiring state member banks to notify it in advance of crypto activities.
Institutional participation has also grown. Binance Research estimated in May 2026 that institutional entities held about 3.88 million BTC, equivalent to 18.5% of Bitcoin's 21 million maximum supply. ETFs accounted for roughly 1.32 million BTC and public companies about 1.24 million BTC. The article notes that U.S. banks are not pursuing a uniform strategy.
ETFs remain the primary access route for most households. Since the SEC approved U.S. spot bitcoin ETFs in January 2024, investors have been able to hold bitcoin exposure in standard brokerage and retirement accounts, with a custodian named in each fund's prospectus holding the underlying coins. Investors should note that each fund charges an annual expense ratio regardless of performance, and that fund share prices track the underlying asset, which has a history of significant volatility.
Looking ahead, the article identifies stablecoins as central to the next phase. The GENIUS Act, signed by President Trump on July 18, 2025, created the first federal framework for payment stablecoins, requiring issuers to back tokens one-for-one with reserves such as U.S. dollars and short-term Treasury bills, and allowing subsidiaries of insured banks to apply to issue them. The article cites cross-border settlement, corporate treasury transfers and payments between fintech companies as potential institutional use cases. The piece cautions that bank offerings vary, and that for most households investing through a fund is simpler than direct custody. It also reminds readers that ETF units, unlike directly held tokens, fluctuate in value and that past performance is not indicative of future results.
The most significant driver of bank engagement has been a shift in federal regulatory posture. On March 7, 2025, the Office of the Comptroller of the Currency said in Interpretive Letter 1183 that national banks may provide crypto-asset custody, engage in certain stablecoin activities and participate in blockchain networks without first obtaining supervisory non-objection. The FDIC followed on March 28, 2025, telling the banks it supervises that they could engage in permissible crypto activities without prior approval. Acting FDIC Chairman Travis Hill said at the time, "With today's action, the FDIC is turning the page on the flawed approach of the past three years." On April 24, 2025, the Federal Reserve Board withdrew its earlier guidance requiring state member banks to notify it in advance of crypto activities.
Institutional participation has also grown. Binance Research estimated in May 2026 that institutional entities held about 3.88 million BTC, equivalent to 18.5% of Bitcoin's 21 million maximum supply. ETFs accounted for roughly 1.32 million BTC and public companies about 1.24 million BTC. The article notes that U.S. banks are not pursuing a uniform strategy.
ETFs remain the primary access route for most households. Since the SEC approved U.S. spot bitcoin ETFs in January 2024, investors have been able to hold bitcoin exposure in standard brokerage and retirement accounts, with a custodian named in each fund's prospectus holding the underlying coins. Investors should note that each fund charges an annual expense ratio regardless of performance, and that fund share prices track the underlying asset, which has a history of significant volatility.
Looking ahead, the article identifies stablecoins as central to the next phase. The GENIUS Act, signed by President Trump on July 18, 2025, created the first federal framework for payment stablecoins, requiring issuers to back tokens one-for-one with reserves such as U.S. dollars and short-term Treasury bills, and allowing subsidiaries of insured banks to apply to issue them. The article cites cross-border settlement, corporate treasury transfers and payments between fintech companies as potential institutional use cases. The piece cautions that bank offerings vary, and that for most households investing through a fund is simpler than direct custody. It also reminds readers that ETF units, unlike directly held tokens, fluctuate in value and that past performance is not indicative of future results.
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