After Ripple Trust Bank Approval, Who Issues RLUSD and Who Manages Its Reserves?

Market Trends

29 October 2026

After the approval of Ripple National Trust Bank, the issuer of RLUSD has not changed. It is still Standard Custody & Trust Company (SCTC), a Ripple subsidiary regulated by New York State. What has changed is reserve management: the newly approved Ripple National Trust Bank (RNTB) will be responsible for managing the segregated reserves backing RLUSD and acting as collateral trustee for the benefit of RLUSD holders. But "managing reserves" does not mean "holding reserves." Day-to-day custody remains with BNY Mellon (BNY). RNTB's role is closer to a federally regulated oversight layer and fiduciary responsibility layer.

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Issuance stays in New York State; the federal charter covers reserves and custody

According to Ripple's official announcement and the OCC approval documents, the issuer of RLUSD is clearly unchanged: Standard Custody & Trust Company (SCTC), a limited purpose trust company regulated by the New York State Department of Financial Services (NYDFS) and a wholly owned subsidiary of Ripple Labs. SCTC handles RLUSD minting, redemption, and related compliance checks. The process described in the whitepaper is that institutional customers deposit U.S. dollars, SCTC performs compliance checks, and then issues RLUSD to the customer's wallet.

The newly approved Ripple National Trust Bank is a national trust bank regulated by the U.S. Office of the Comptroller of the Currency (OCC). Its approved business scope includes managing RLUSD's segregated reserves, acting as collateral trustee for the benefit of RLUSD holders, and providing trust-based digital asset custody services. The OCC documents also note that this type of national trust bank cannot accept deposits or make loans, which is different from a traditional commercial bank charter.

In other words, RLUSD is now under a two-layer regulatory structure: the issuance side remains under NYDFS, while the reserve management and custody side now has federal oversight from the OCC. The Block's report describes this structure as "reserve management and custody under federal oversight, while issuance remains with a New York state-regulated entity."

BNY remains the primary custodian; RNTB's role needs to be understood accurately

One easy misunderstanding is whether RNTB "managing" reserves means all U.S. dollars and Treasury securities backing RLUSD have moved to RNTB's books. Ripple's announcement also states another key point: BNY (Bank of New York Mellon) continues to serve as the primary reserve custodian for RLUSD. RLUSD reserves consist of U.S. dollar deposits, U.S. government securities, and other cash equivalents. Monthly independent third-party attestation reports cover circulating supply and reserve assets.

RNTB's function is more accurately described as managing segregated reserves within a trust framework and acting as collateral trustee on behalf of RLUSD holders. This gives it a legal fiduciary duty, but in practical terms, the day-to-day custody of reserve assets remains with BNY. Brave New Coin's analysis also points out that RNTB's role in managing segregated reserves operates within the existing custody arrangement framework, "rather than meaning all reserve assets will immediately move to this new institution."

What this means for RLUSD holders

If you care about whether "my RLUSD is backed by U.S. dollars," the verifiable materials remain Ripple's monthly third-party attestation reports and the BNY custodian arrangement. RNTB's approval adds a layer of federal oversight and fiduciary duty, but the transparency and verifiability of reserve assets do not automatically improve because of the new bank charter. They still depend on the existing monthly attestation mechanism.

If you care about whether "RLUSD will become a stablecoin directly regulated by the OCC," the answer is no. The entry point for issuance and redemption remains with SCTC, and NYDFS remains the direct regulator of the issuance side. RNTB's role gives the reserve management side a federal regulatory handle, but the OCC does not directly approve each RLUSD issuance.

One point to keep watching is whether the actual operation of reserve management changes after RNTB officially begins operations. If Ripple adjusts the custody division of labor between BNY and RNTB in the future, or if the scope and frequency of attestation report disclosures change, that would be a real signal affecting RLUSD reserve transparency. Until then, the existing monthly attestation and BNY custody arrangement remain the primary basis for assessing the assets behind RLUSD.

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After Ripple Trust Bank Approval, Who Issues RLUSD and Who Manages Its Reserves?

Issuance stays in New York State; the federal charter covers reserves and custody

BNY remains the primary custodian; RNTB's role needs to be understood accurately

What this means for RLUSD holders

References