iTechGuides is reader-supported. When you buy through links on our site, we may earn an affiliate commission. As an Amazon Associate I earn from qualifying purchases. Learn more
Yes. A U.S. bank does not need the CLARITY Act to serve a crypto company when the specific service is permitted under applicable federal and state law and the bank can manage the associated risks. Existing banking authority and agency actions cover certain activities, but they do not approve every crypto business model or require a bank to accept any particular customer.
What the CLARITY Act does—and does not—decide
The Digital Asset Market Clarity Act of 2025, H.R. 3633, is a proposed market-structure bill. The House materials describe a framework for digital commodities and the roles of the SEC and CFTC. It is not a general legal prerequisite for a crypto company to open a bank account or obtain other banking services.
The materials available for this article do not establish the bill’s latest Senate status as of October 4, 2026. That uncertainty does not change the narrower answer: banks may provide services for permissible activities under existing law, subject to supervision and risk controls. The bill’s status should not be confused with whether a bank already has authority to conduct a particular activity.
What existing law allows banks to do
GENIUS Act: preserved authority, not blanket approval
Enacted in July 2025 as Public Law 119-27, the GENIUS Act says its chapter does not limit a depository institution, credit union, national bank, or trust company from conducting activities permissible under applicable state and federal law. The statute gives examples including taking deposits, using distributed-ledger technology for institutional records and intrabank transfers, and providing custody of payment stablecoins, private keys, or stablecoin reserves.
#1 Best Overall
- Effortlessly build your crypto portfolio via the all in one Ledger Wallet app: buy, sell, send, receive, swap, stake and more across popular blockchains. 15,000+ coins & tokens in a single dashboard. Keep a close eye on the market. Compare service providers. Track performance. Get timely alerts. Build your portfolio with confidence.
- Effortlessly build your crypto portfolio via the all in one Ledger Wallet app: buy, sell, send, receive, swap, stake and more across popular blockchains. 15,000+ coins & tokens in a single dashboard. Keep a close eye on the market. Compare service providers. Track performance. Get timely alerts. Build your portfolio with confidence.
- Enjoy Bluetooth connectivity, iOS access, and hours of battery use with this mobile-first, secure backup signer. Freedom you can depend on.
- Genuine Check: confirm your signer is authentic during setup with the Ledger Wallet app.
- Protect your signer: keep it in mint condition at all times with a bespoke Pod or Case to avoid scratches and everyday wear and tear.
The key condition is that an activity must already be permissible under other applicable law. These examples preserve or clarify authority; they do not automatically authorize every token, trading, lending, or other crypto-related business activity.
OCC-chartered institutions
On March 7, 2025, the Office of the Comptroller of the Currency issued Interpretive Letter 1183. It reaffirmed that national banks and federal savings associations may provide crypto-asset custody, engage in certain stablecoin activities, and participate in independent node verification networks, subject to applicable law and appropriate risk controls.
Rank #2
- Proven security at scale: Over 9 years and millions of cards issued with no known remote hacks, while military‑grade EAL6+ security keeps your private keys locked inside the chip. Your cryptocurrencies stay strongly protected from online attackers.
- Tap once to manage your entire crypto wallet across 90 blockchains - no USB cables or Bluetooth, no batteries, no setup. Access 14,100+ coins & tokens, DeFi, NFTs, and staking instantly from your phone
- Smart backup: Use your second Tangem Wallet as your Backup keys with end‑to‑end encryption; no more papers, pictures. If one card is lost, the remaining can still restore full access, with an optional seed phrase available for advanced users.
- Engineered to last up to 25 years: Waterproof (IP69K), shockproof and tested for extreme temperatures from −25°C to 50°C. A durable cold wallet with long‑term protection and independently audited security.
- Trusted by 6 million users worldwide (4.9 App Store, 4.8 Google Play) - buy, sell, swap, stake, and spend cryptocurrency directly. The secure offline storage wallet designed for how people actually use crypto wallets
FDIC-supervised institutions
On March 28, 2025, the Federal Deposit Insurance Corporation rescinded FIL-16-2022, which had required prior notification for crypto-related activities by FDIC-supervised institutions. The FDIC said such institutions may engage in permissible crypto-related activities without prior FDIC approval if they adequately manage the associated risks. This change concerns the prior-notification process; it is not an exemption from other legal requirements or supervision.
How the activity changes the analysis
| Service or activity | What the cited authorities establish | Practical qualification |
|---|---|---|
| Ordinary deposit relationship | The GENIUS Act names taking deposits as an example of activity not limited by that chapter. | The underlying business and account use still need to comply with applicable law and the bank’s requirements. |
| Payment stablecoins and reserves | The GENIUS Act addresses payment stablecoins; the OCC reaffirmed certain stablecoin activities for national banks and federal savings associations. | These authorities do not establish that every stablecoin arrangement or issuer is permissible. |
| Custody and safekeeping | The GENIUS Act names custody of payment stablecoins, private keys, and reserves; the OCC reaffirmed certain crypto-asset custody authority. | Custody requires controls for risk management and safekeeping, alongside continued attention to safety, soundness, and supervision. |
| Distributed-ledger operations | The GENIUS Act names ledger use for institutional records and intrabank transfers; the OCC addressed participation in independent node verification networks. | Permission depends on the precise activity and the institution’s charter, applicable law, and controls. |
This is not a complete catalogue of permitted or prohibited crypto activities. A company’s precise business model matters: a deposit account, stablecoin reserve arrangement, custody service, and network operation raise different legal and operational questions.
Rank #3
- Proven security at scale: Over 9 years and millions of cards issued with no known remote hacks, while military‑grade EAL6+ security keeps your private keys locked inside the chip. Your cryptocurrencies stay strongly protected from online attackers.
- Tap once to manage your entire crypto wallet across 90 blockchains - no USB cables or Bluetooth, no batteries, no setup. Access 14,100+ coins & tokens, DeFi, NFTs, and staking instantly from your phone
- Smart backup: Use your second Tangem Wallet as your Backup keys with end‑to‑end encryption; no more papers, pictures. If one card is lost, the remaining can still restore full access, with an optional seed phrase available for advanced users.
- Engineered to last up to 25 years: Waterproof (IP69K), shockproof and tested for extreme temperatures from −25°C to 50°C. A durable cold wallet with long‑term protection and independently audited security.
- Trusted by 6 million users worldwide - buy, sell, swap, stake, and spend cryptocurrency directly. The secure offline storage wallet designed for how people actually use crypto wallets
Why permission does not guarantee an account
Regulatory authority means a bank may be able to conduct a permissible activity; it does not mean a specific company is entitled to banking access. The cited laws and agency actions do not require a bank to onboard a particular crypto business. Banks make institution-specific decisions, including whether they can understand, monitor, and manage a prospective customer’s risks while meeting their legal obligations.
For a company seeking service, it is useful to identify the exact account or service requested, explain how funds and digital assets move, and be prepared to describe relevant compliance and custody controls. These are practical ways to clarify the activity under review, not a guarantee of approval.
Rank #4
- EAL5+ CERTIFIED SECURE ELEMENT + FINGERPRINT PROTECTION — Your private keys stay encrypted offline on a certified EAL5+ chip, the same security tier used in EMV bank cards. Built by DCENT, securing crypto since 2018. Fingerprint authentication adds a second layer no PIN-only wallet can match.
- 10,000+ ASSETS NATIVE ON 100+ BLOCKCHAINS — Hold Bitcoin, Ethereum, XRP, Solana, Cardano, popular stablecoins (USDT, USDC), and NFTs in one wallet. No third-party apps, no fragmented setup — every supported asset works straight out of the box.
- TAP-TO-SIGN MOBILE EXPERIENCE — Pair your wallet with the DCENT mobile app over Bluetooth. Manage tokens, review transactions, and access in-app swap features directly from your phone — no cables, no desktop required.
- WEB3 & dAPP ACCESS VIA METAMASK — Connect to MetaMask and other browser extension wallets to manage NFTs, claim airdrops, and access dApps. A large screen and intuitive 4-button interface keep every transaction clearly visible before you sign.
- SEAMLESS FIRMWARE UPDATES & 30-DAY MONEY-BACK GUARANTEE — Apply security updates without resetting your wallet or migrating funds. Backed by Amazon's 30-day money-back guarantee — your purchase is risk-free.
What banks still have to do
Ending or changing a prior notification process does not remove a bank’s responsibility to operate safely, soundly, and in compliance with applicable requirements. The OCC’s May 2025 bulletin reports a joint statement by the OCC, Federal Reserve Board, and FDIC on crypto-asset safekeeping services, emphasizing risk-management controls and continuing supervisory attention. A bank must assess the risks of the service it provides, especially when it safeguards assets or keys.
What’s actually slowing this PC down?
Pick the symptom - the matching free tool is one click away.
Separately, on April 7, 2026, the FDIC approved a proposed rule on GENIUS Act standards for permitted payment-stablecoin issuers and insured depository institutions, reserve deposits, deposit-insurance treatment, and tokenized deposits. It was a proposal, not a final rule; it should not be described as settled requirements.
Quick Recap
Best Value
- Dual-chip architecture for maximum protection: The next-gen, fully auditable TROPIC01 chip works alongside a certified EAL6+ Secure Element—completely NDA-free—to deliver radically transparent, industry-leading defense against physical attacks.
- Quantum-ready security: Get protection against future threats with the first-ever hardware wallet designed with quantum-ready architecture.
- See every detail with confidence: Our largest high-resolution color touchscreen makes it easy to navigate your assets, review transactions and manage your coins with clarity.
- Wireless freedom with encrypted Bluetooth control: Manage, buy, swap and stake securely using Trezor Suite on desktop or mobile. Qi2-compatible wireless charging keeps your Trezor powered up. No cables required—security meets convenience.
- Works seamlessly with Android, iOS and desktop: Connect wirelessly or via USB-C to your phone or computer. Manage your crypto anywhere with our companion Trezor Suite app.
How to read the answer for a particular company
- Define the service. Specify whether the need is a deposit account, payment-stablecoin activity, reserves, custody, or distributed-ledger operation.
- Identify the institution and oversight. OCC authorities discussed here concern national banks and federal savings associations; the FDIC notification change concerns FDIC-supervised institutions. State and other federal law may also apply.
- Check the activity’s legal basis. The GENIUS Act preserves activities that are permissible under applicable law; it is not a standalone approval for a business model.
- Discuss controls and the bank’s decision. Risk management remains relevant, and regulatory permission does not compel a bank to accept the applicant.
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
