51 Insights

51 Insights

CEO Notes

The GENIUS Act’s first victims

Traditional bank moats

Marc Baumann's avatar
Sangam Bharti's avatar
Marc Baumann and Sangam Bharti
Dec 23, 2025
∙ Paid

The traditional banking system just lost control of its most important moat: exclusivity. For decades, the OCC’s charter approval process was the ultimate gatekeeping mechanism, determining who could offer trust services and custody to America’s institutions.

But on December 12, 2025, the regulator changed the rules. It approved five national trust bank …

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