The OCC's 376-page proposed rule under the GENIUS Act is converting stablecoin policy into binding compliance requirements with formal issuer categories. Paxos, BitGo, and Ripple all received OCC trust charter approvals, but a trust charter does not guarantee Fed payment rail access. Klarivis data shows deposit movement from stablecoin-adjacent products is already measurable at community banks. The 26-month application timeline puts anyone starting today against a potential administration change, and sponsor bank programs face new pressure from charter competition and yield-based products.

Bank charter confusion, trust charter risks, and Fed Master Account access gaps are creating real problems for fintech operators, sponsor banks, and community bank executives right now. Tedd Huff, CEO of fintech advisory firm Voalyre and founder of Fintech Confidential, and co-host Steve Bishop sit down on Inside the Vault with three former and current regulatory insiders: Syed Raza, former Acting Chief Innovation Officer at the OCC and Managing Director at FTI Consulting; Michele Alt, Co-Founder and Managing Director at Klaros Group; and Ian Moloney, Chief Policy Officer at the American Fintech Council.

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1️⃣ Answer four questions before filing: who grants the charter, what powers it includes, what activities are limited, and who examines the institution.

2️⃣ Start compliance documentation now; controls, funds flow maps, and exception handling should be ready before the examiner asks.

3️⃣ Read the conditions attached to charter approvals; those conditions reveal what regulators did not trust in the application.

4️⃣ Align cost sharing, control ownership, and data ownership with your partner before examination forces the conversation.

5️⃣ Price the M&A path into your charter strategy; the 26-month timeline means the political window may close before your application clears.

Guest Links

Syed Raza

FTI Consulting

Michele Alt

Klaros Group

Ian Moloney

American Fintech Council

Steve Bishop

Fintech Confidential

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Supporters

Under: Streamline your application and underwriting process by digitizing PDFs for digital signature. under.io/ftc

Skyflow: Zero-trust data privacy vault delivered as an API covering PCI, CCPA, GDPR, and SOC 2 compliance. skyflowsecure.com

Hawk AI: Real-time payment screening, ML transaction monitoring, and dynamic customer risk rating to fight fraud and financial crime. gethawkai.com

About the Guests

Syed Raza is a Managing Director at FTI Consulting with over 30 years in risk management and regulatory compliance. He previously served as Acting Chief Innovation Officer at the OCC, guiding regulatory policy for fintech licensing.

Michele Alt is Co-Founder and Managing Director at Klaros Group. She spent 22 years in the OCC Law Department and advises banks and fintechs on charter applications, regulatory strategy, and bank design.

Ian Moloney is Chief Policy Officer at the American Fintech Council. He previously led policy and regulatory affairs at Cross River and served as a Senior Analyst at the U.S. Government Accountability Office.

About the Co-Host

Steve Bishop is Founder and Chief Ally at amBaaSsador, an education and advisory platform focused on embedded finance and Banking-as-a-Service for financial institutions.

About the Host

Tedd Huff, CEO of fintech advisory firm Voalyre and host of Fintech Confidential. Fintech Confidential is a production of DD3 Media, bringing you the people, tech, and companies that change how you pay and get paid.

Chapters

00:00 Episode Highlights

00:36 Welcome to Fintech Confidential

03:31 Sky Flow: Building Fast and Secure (Sponsor)

04:33 What a Charter Means

07:06 OCC Rules and Stablecoins

09:43 Why Trust Charters Boom

13:50 Under.io: AI-Powered Onboarding & Risk Verification (Sponsor)

14:20 Fed Master Account Gap

17:59 Sponsor Banking Under Pressure

22:15 What to Watch Next

25:28 Action Steps and Wrap

27:50 Hawk.ai: AI-Driven Financial Crime Detection (Sponsor)

28:36 Disclaimer

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