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A US national bank cleared to set up a stablecoin issuing subsidiary, including for third parties

The Office of the Comptroller of the Currency released Corporate Decision #1388 on 3 September 2026. Signed on 23 July, it lets SoFi Bank, National Association form a subsidiary to issue and redeem payment stablecoins, including on behalf of third-party clients. The approval carries a single GENIUS Act compliance condition and lapses if the subsidiary is not formed within 12 months.

The Office of the Comptroller of the Currency, the federal regulator of nationally chartered banks in the United States, released Corporate Decision #1388 on 3 September 2026. It clears SoFi Bank, National Association to set up an operating subsidiary that will issue and redeem payment stablecoins. The letter is dated 23 July 2026, and it answers an application filed on 27 March.

What the subsidiary may do

Under US federal law, a payment stablecoin is a digital asset designed to serve as a means of payment or settlement. Its issuer undertakes to redeem it for a fixed amount of monetary value and represents that it will maintain a stable value. The decision sets out the future subsidiary's business: issuing and redeeming such stablecoins, both those carrying the bank's own brand and those issued on behalf of third-party clients. The second limb puts a white-label offer inside the perimeter of a national bank.

The OCC grounds its approval in 12 CFR 5.34(e), which lets a national bank house in an operating subsidiary the activities it could carry on directly. It finds those activities permissible for national banks and their subsidiaries, and the structure compliant with 12 CFR 5.34(e)(2).

27 March 2026
Application filed
SoFi Bank files an operating subsidiary application, logged as control number 2026-Subs&Equities-34542.
23 July 2026
Approval letter
The authorisation is signed, subject to a single condition.
3 September 2026
Payward agreement
The listing of SoFiUSD is announced, along with Payward's connection to the SoFi Exchange Network.
3 September 2026
Publication
The OCC's compendium of corporate decisions carries the text, six weeks to the day after signature.
23 July 2027
Formation deadline
The date after which the approval lapses if the subsidiary does not exist.

Why a subsidiary rather than the bank

The GENIUS Act, enacted on 18 July 2025 as Public Law 119-27, lists who may issue a payment stablecoin. The list runs to three entries: a subsidiary of an insured depository institution approved under section 5904, a Federal qualified payment stablecoin issuer, and a State qualified payment stablecoin issuer. The insured depository institution does not appear in its own right; only its subsidiary does. The structure SoFi Bank has chosen follows that form.

Section 5904 sets the regulator's clock: 30 days to say whether the filing is substantially complete, 120 days to approve or deny. An application left undecided at the end of that period is approved automatically.

⚠️
Two separate steps
The 23 July letter rules on an operating subsidiary application and rests on 12 CFR 5.34(e). It does not present itself as the approval provided for in section 5904 of the GENIUS Act, and it defers compliance with that Act to a condition to be met afterwards.
A hand holds a pen over a stamped official document.
The approval runs to two pages and sets a single condition, with the OCC alone judging compliance.

The condition, and the date behind it

The approval carries a single condition. If and to the extent it becomes necessary, the bank must conform, cease or divest its proposed stablecoin issuance and redemption activities, along with any other activities. The duty runs to the GENIUS Act, its implementing regulations and any other applicable laws and regulations that take effect in the future. The OCC alone judges that compliance. The letter labels the clause a condition imposed in writing by a federal banking agency within the meaning of 12 USC 1818, which makes it enforceable under that section.

That condition points at rules that have yet to take effect. The GENIUS Act takes effect on the earlier of two dates: 18 months after enactment, that is 18 January 2027, or 120 days after the federal regulators issue final implementing regulations. The subsidiary can therefore be formed before the issuer regime applies.

If the subsidiary is not established within 12 months of the letter's date, the approval lapses automatically unless the OCC grants an extension. The OCC also reserves the right to rescind it if a material change affects the information it relied on.

27 March 2026
Subsidiary application filed
OCC, Corporate Decision #1388
18 January 2027
Latest date the GENIUS Act takes effect
Legal Information Institute, 12 U.S. Code § 5901

The Kraken link, announced the same day

An exchange platform screen showing a price chart on a dark background.
Payward will list SoFiUSD on Kraken and will join SoFi's settlement network.

SoFi Technologies and Payward, Kraken's parent, announced their partnership on 3 September 2026, the same day the decision was released. Payward joins the SoFi Exchange Network, a real-time settlement network that lets institutional clients clear and settle US dollar transactions 24 hours a day, seven days a week. SoFi in turn will use Kraken Prime as a source of digital asset liquidity.

The release calls SoFiUSD a bank-issued stablecoin and speaks of widening access to it. American Banker reported on 4 September that the stablecoin was already open to SoFi's banking customers before that announcement. The group claims 15.8 million members. Corporate Decision #1388 grants an authorisation. The subsidiary has still to be formed, and its compliance with the GENIUS Act still to be established.

Provenance

Published on 4 September 2026

6 sources, 5 distinct domains

OCC, Corporate Decision #1388, Operating Subsidiary Application, SoFi Bank, National Association · occ.govSoFi Technologies, SoFi and Payward Partner to Connect Banking and Digital Asset Markets · investors.sofi.comAmerican Banker, SoFi-Kraken partnership connects banking, digital assets · americanbanker.comPYMNTS, SoFi and Payward Team to Link Banking and Digital Asset Markets · pymnts.comLegal Information Institute, 12 U.S. Code § 5901, Definitions · law.cornell.eduLegal Information Institute, 12 U.S. Code § 5904, Approval of subsidiaries of insured depository institutions · law.cornell.edu
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