The U.S. banking system might be going through one of its biggest changes in years without much public attention. The EGRPRA review (Economic Growth and Regulatory Paperwork Reduction Act), which takes place only once every decade, is now underway and will continue until July 2026.
This review allows top financial regulators, the OCC, Federal Reserve, and FDIC, to update banking laws without needing Congress to act. It’s a rare opportunity to redefine what a bank is and how financial services work in a digital world.
EGRPRA Review May Quietly Reshape U.S. Finance
At the center of this potential shift is Ripple. The company has applied for a national trust bank charter, which would allow it to operate in a completely different way from traditional banks.
Instead of taking deposits or offering loans, Ripple’s trust would:
Legal expert Mr. Man referred to this review as a “legal bypass,” meaning regulators can make significant changes to financial rules without the usual political process.
Ripple’s Application and the Fed’s Fast-Track Clause
Mr. Man points to Section 12 CFR § 262.3, which governs how the Fed processes such applications. Typically, once Ripple’s application is made public, there’s a 90-day window for review.
However, the Fed can bypass this entirely if it deems the application critical to system stability or liquidity. That clause could give Ripple an express lane to approval if its services are seen as essential for the evolving tokenized economy.
Mr. Man adds that Ripple’s success would mark a turning point in redefining legal personhood in the financial system, from paper charters to programmable code.
Can Ripple Get Fast-Tracked?
According to Federal Reserve regulations under 12 CFR § 262.3, once Ripple’s application is made public, a formal 90-day window opens for review and public comment. During this time, the Fed can approve, reject, or require the application to be resubmitted.
However, there’s a lesser-known clause that gives the Board the power to waive these procedures entirely if “immediate action is necessary to prevent failure” or if there is an emergency.
This clause gives regulators the flexibility to fast-track Ripple’s approval if they consider it critical to liquidity, interoperability, or systemic financial stability.
What Could This Mean by 2026?
By the time the EGRPRA review ends in 2026, the U.S. may have quietly created space for a new type of financial institution, programmable, blockchain-based entities that operate under traditional regulation but with entirely digital tools.
Ripple’s trust bank could be one of the first, handling smart contracts and stablecoins just like banks handle checks and wires today.
A New Financial Framework, Built in Plain Sight
This shift won’t come with headlines or big announcements. But analysts believe it could mark the beginning of a financial system where code, tokens, and blockchains operate side by side with traditional finance all legally approved under U.S. law.
Ripple may just be the first to cross that line.
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FAQs
The EGRPRA review is a rare, decade-long process (ending July 2026) allowing top U.S. financial regulators to update banking laws without Congress, potentially reshaping the U.S. financial system for digital assets.
Ripple’s application aims to establish a new type of financial institution that manages stablecoin reserves and settles tokenized assets, potentially redefining banking in a digital world without traditional deposits or loans.
By 2026, the EGRPRA review could quietly create a legal framework for new, programmable, blockchain-based financial institutions in the U.S., allowing code, tokens, and blockchains to operate alongside traditional finance.
