Wise plans to resubmit national trust bank application under GENIUS Act framework

Quick Take

• William Blair said that while Wise is resubmitting its national trust bank charter application under a GENIUS Act framework, the analysts do not predict "a major shift in the company's stance on stablecoins."
• The OCC has granted conditional approval to several stablecoin-focused entities since December, six months after the GENIUS Act passed, legislating payment stablecoin activities.

Wise plans to submit a new application for a national trust bank charter in the U.S. under the GENIUS Act stablecoin framework after the Office of the Comptroller of the Currency denied its original application, according to a William Blair note on Friday.

The OCC said that Wise's application was incompatible with new ⁠Federal Reserve policies regarding payment system Master Account access.

Reuters reported that Wise would reapply on Friday. The OCC's denial was made in a July 21 letter.

"While approval would have represented a step towards a connection to U.S. domestic rails, we understand the Fed has essentially halted the granting of master accounts, as it develops policies for 'payment accounts' that were formally proposed in May 2026," William Blair analysts Cristopher Kennedy and Marc Feldman wrote.

The OCC, along with other major financial regulators in the U.S., has radically reshaped its approach to oversight during President Donald Trump's second term.

Last December, the OCC granted conditional approvals to banking charter applicants including entities affiliated with BitGo, Circle, Fidelity, Paxos and Ripple, which intend to provide stablecoin services. That same month, BitGo was granted full approval to convert its state trust company into a federally regulated entity.

Since then, Crypto.com, Coinbase and Nomura-backed Laser Digital National Trust Bank have received conditional approval, while Sony Bank subsidiary Connectia was approved. Upstart received conditional approval for Upstart Bank, which is focused more on AI than digital assets.

Many other crypto firms and traditional financial giants that are increasingly interested in stablecoins, like Morgan Stanley and Charles Schwab, have started their OCC application processes.

Circle won official charter status earlier this month, joining BitGo and Anchorage Digital, which had for years been the only crypto firm holding a national trust charter, granted in 2021.

Meanwhile, the Federal Reserve Bank of Kansas City approved a limited-purpose "master account" for Wyoming-chartered bank Kraken Financial in March, making it the first crypto firm with direct access to Fed payment rails like Fedwire.

The GENIUS Act passed in the summer of 2025, offering set rules for so-called "payment stablecoins," or assets designed to keep a peg to the U.S. dollar by keeping safe reserves like cash or Treasuries in custody.

Of note, Reuters reported that Wise's denial addressed specific historical compliance concerns, including a July 2025 multi-state consent order over anti-money laundering risk management issues that Wise says it has since strengthened.

Wise's initial plan also relied on having a Fed Master Account, which was made non-viable by the Fed's formal proposal for limited "payment accounts" that included a temporary pause on Tier-3 access requests by (uninsured, non-federally supervised entities.

Wise said its infrastructure is built to interoperate with both blockchain and traditional payment rails, though the firm remains agnostic on stablecoins, Reuters reported.

"Although Wise plans to submit a new application under a Genius Act framework, we do not anticipate a major shift in the company's stance on stablecoins --- Wise is focused on lowering the cost of cross-border transactions, agnostic of the rail," William Blair said.

William Blair reiterated its Outperform rating on WISE, saying its discounted cash flow (DCF) "implies at least a $19 stock price."

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