> ## Content Index > Fetch the complete content index at: https://stablecoininsider.org/llms.txt > Use this file to discover other available public pages before exploring further. # Jonathan Gould OCC: From Bitfury to the GENIUS Act Rule - URL: https://stablecoininsider.org/jonathan-gould-occ/ - Published: 2026-10-27T13:33:35.000Z - Updated: 2026-10-27T13:33:37.000Z - Description: Jonathan Gould, the 32nd Comptroller of the Currency, signed off on the OCC's GENIUS Act final rule on 21 October 2026 and is chartering stablecoin trust banks for Circle, Ripple and others. His career timeline, the charter numbers and what issuers should expect next. - Author: Alexandra - Tags: Leaders, Stablecoins, GENIUS Act Jonathan Gould is the regulator most stablecoin issuers now have to win over. As the 32nd Comptroller of the Currency, he took office on 15 July 2025, days before the GENIUS Act became law, and his agency issued its final rule implementing that law on 21 October 2026 ([OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-70.html); [OCC News Release 2026-92](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). Five days later, on 26 October, Ripple said the OCC had granted final approval for Ripple National Trust Bank, following Circle's final trust bank approval in July ([Ripple](https://ripple.com/ripple-press/ripple-receives-final-occ-approval-to-establish-national-trust-bank/); [Circle](https://www.circle.com/pressroom/circle-receives-final-occ-approval-to-establish-national-trust-bank)). This profile covers who Jonathan Gould is, how a former Bitfury chief legal officer ended up writing the rulebook for US dollar stablecoins, the charter numbers behind his tenure, and what his OCC is likely to ask of the next wave of applicants. Stablecoin Insider built a career timeline, a charter scorecard and a rule clock from OCC documents, so you can see the pattern for yourself. ### Key Takeaways - Gould was sworn in as Comptroller on 15 July 2025 after a 50 to 45 Senate confirmation vote on 10 July ([Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29)). - Before returning to the OCC, he was chief legal officer at blockchain firm Bitfury and then a partner at Jones Day ([Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29)). - He said 23 of 40 new charter applications in about 18 months involved digital assets, an eightfold increase on the prior four years ([OCC](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-69.html)). - The OCC's GENIUS Act final rule was announced on 21 October 2026 and takes effect on 18 January 2027 ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). - Circle (10 July 2026) and Ripple (26 October 2026) have won final OCC approval for national trust banks ([Ripple](https://ripple.com/ripple-press/ripple-receives-final-occ-approval-to-establish-national-trust-bank/)). ## Who is Jonathan Gould? Jonathan V. Gould is the Comptroller of the Currency, the administrator of the federal banking system and head of the Office of the Comptroller of the Currency (OCC). The agency supervises more than 1,000 national banks, federal savings associations and federal branches of foreign banks, and the Comptroller also sits on the FDIC board and the Financial Stability Oversight Council ([OCC biography](https://www.occ.gov/about/who-we-are/comptroller/index-comptroller-of-the-currency.html)). He is a banking lawyer by training, with a bachelor's degree from Princeton University and a law degree from Washington and Lee University. The OCC's own biography says he has spent the bulk of his career in the private sector as a consultant and lawyer, advising banks and other financial firms on regulation and risk ([OCC biography](https://www.occ.gov/about/who-we-are/comptroller/index-comptroller-of-the-currency.html)). For stablecoin readers, the important part is that this is his second tour at the OCC. As Senior Deputy Comptroller and Chief Counsel from 2018 to 2021, he oversaw the agency's legal and licensing work, and his Jones Day profile says that under his direction the OCC "chartered the first fintech and crypto banks" and "recognized crypto-related activities as permissible" ([SIFMA profile](https://www.sifma.org/people/jonathan-gould)). ### Jonathan Gould career timeline | Date | Milestone | Source | | ------------ | --------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------- | | 2001 | Earns a law degree from Washington and Lee University and joins Alston & Bird as an associate | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | 2005 to 2008 | Counsel, US Senate Committee on Banking, Housing, and Urban Affairs | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | 2008 to 2018 | Promontory Financial Group, then BlackRock | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | Feb 2018 | Returns to the Senate Banking Committee as chief counsel | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | 24 Dec 2018 | Becomes OCC Senior Deputy Comptroller and Chief Counsel under Joseph Otting | [OCC](https://www.occ.gov/news-issuances/news-releases/2018/nr-occ-2018-145.html) | | Jun 2021 | Leaves the OCC | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | Feb 2022 | Chief legal officer at blockchain firm Bitfury | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | Sep 2022 | Partner at Jones Day | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | 11 Feb 2025 | Nominated as Comptroller of the Currency | [OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-70.html) | | 10 Jul 2025 | Confirmed by the Senate, 50 to 45 | [Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29) | | 15 Jul 2025 | Sworn in as the 32nd Comptroller | [OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-70.html) | | 12 Dec 2025 | OCC conditionally approves five national trust bank charters, including Circle and Ripple | [OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html) | | 14 Aug 2026 | Preliminary conditional approval for World Liberty Trust Company | [OCC](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf) | | 19 Aug 2026 | Wyoming Blockchain Symposium: 23 of 40 charter applications involve digital assets | [OCC](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-69.html) | | 21 Oct 2026 | OCC announces its GENIUS Act final rule | [OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html) | | 26 Oct 2026 | Ripple National Trust Bank receives final approval | [Ripple](https://ripple.com/ripple-press/ripple-receives-final-occ-approval-to-establish-national-trust-bank/) | The thread through the timeline is that Gould has worked on almost every side of a bank charter: as a Senate staffer writing law, a consultant advising applicants, the OCC's chief counsel approving them, and a lawyer for a crypto company. That mix shows up in how his OCC talks about stablecoins: as a licensing question first, and a technology question second. ## Jonathan Gould's charter push Gould's clearest public theme is reopening the charter door. In August 2026 the OCC said that from 2011 through 2014 it received fewer than four charter applications a year on average, and that it had received 40 de novo applications in the last 18 months, often deciding within 120 days of a complete file ([OCC News Release 2026-67](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-67.html)). He has tied that push directly to digital assets. "Entities that engage in legally permissible activities, including those involving digital assets and other novel technologies, should have a path to becoming a national bank," Gould said in the same release, adding: "America and the OCC are once again open for business" ([OCC](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-67.html)). At the Wyoming Blockchain Symposium on 19 August 2026 he put numbers on it: 23 of the 40 applications involved some form of digital asset activity, "an eightfold increase from the four years of the Biden administration," and it is "becoming ordinary course to involve and integrate payment stablecoins" in new business plans ([OCC News Release 2026-69](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-69.html)). He also pushed back on the idea that the OCC should shield existing banks. The ABA Banking Journal reported him saying his job isn't about "incumbent protection" but about preserving the integrity of the banking system ([ABA Banking Journal](https://bankingjournal.aba.com/2026/08/occs-gould-defends-charter-approvals-for-crypto-activity/)). ### Stablecoin charter scorecard | Applicant | OCC step | Tier 1 capital floor | Multiple of $5M rule floor | Source | | --------------------------------------------- | ------------------------------------------------------------ | -------------------- | -------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | Circle (First National Digital Currency Bank) | Conditional 12 Dec 2025; final 10 Jul 2026 | $6.05M | 1.21x | [OCC letter](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125a.pdf); [Circle](https://www.circle.com/pressroom/circle-receives-final-occ-approval-to-establish-national-trust-bank) | | Ripple National Trust Bank | Conditional 12 Dec 2025; final 26 Oct 2026 | $11.7M | 2.34x | [OCC letter](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125b.pdf); [Ripple](https://ripple.com/ripple-press/ripple-receives-final-occ-approval-to-establish-national-trust-bank/) | | World Liberty Trust Company | Preliminary conditional 14 Aug 2026 | $20M | 4.00x | [OCC letter](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf) | | BitGo, Fidelity Digital Assets, Paxos | Conditional conversions to national trust banks, 12 Dec 2025 | Not in the release | n/a | [OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html) | Multiples are Stablecoin Insider calculations against the $5 million capital floor in the OCC's GENIUS Act final rule ([final rule](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92a.pdf)). Two readings follow. Charter capital is set case by case and, in all three letters, sits above the rule's floor. And the path from conditional to final approval took 210 days for Circle and 318 days for Ripple, measured from 12 December 2025. For the mechanics of Ripple's approval, see Stablecoin Insider's breakdown of [Ripple National Trust Bank and what final OCC approval means](https://stablecoininsider.org/ripple-national-trust-bank/). A national trust bank is not a deposit bank: the OCC has said its December approvals joined approximately 60 national trust banks it already supervised ([OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html)). 💡 Stablecoin Insider's take: Gould's OCC is selling speed and certainty, not leniency. Each of the three issuer approval letters reviewed here carries a capital floor above the GENIUS Act minimum, and the final rule replaced hard liquidity ratios with examiner judgment. Issuers should expect a supervisor that says yes faster, then watches closely. ## The GENIUS Act rule Gould signed off on The OCC's final rule sets requirements for permitted payment stablecoin issuers and foreign issuers under its jurisdiction, plus certain custody activities. Anti-money laundering and sanctions rules are being handled in a separate rulemaking with the Treasury ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). It was printed in the Federal Register on 23 October 2026 ([Federal Register](https://www.federalregister.gov/documents/2026/10/23/2026-21706/implementing-the-guiding-and-establishing-national-innovation-for-us-stablecoins-act-for-the)). Gould's framing at launch: "We are providing a clear, practical framework for payment stablecoin innovation, with strong standards for reserve backing, redemption, and risk management" ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). Treasury Secretary Scott Bessent compared the GENIUS Act to the National Currency Act of 1863 in the same release. - Capital: a $5 million floor plus an operational backstop equal to 12 months of total expenses ([final rule](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92a.pdf)). - Liquidity: daily liquidity of at least 5% of reserves, down from 10% in the March proposal ([final rule](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92a.pdf)). - Comments: about 328 comment letters on the proposal ([final rule](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92a.pdf)). - Yield: direct issuer yield stays banned, while arrangements through third parties are judged case by case ([ABA Banking Journal](https://bankingjournal.aba.com/2026/10/occ-finalizes-stablecoin-rule-with-narrow-payment-of-interest-prohibition/)). Banks wanted a tougher line. The OCC dropped the proposal's presumption against yield paid through affiliates and partners, and said it expects to propose a rule "clarifying the yield prohibition" once it has more supervisory experience ([ABA Banking Journal](https://bankingjournal.aba.com/2026/10/occ-finalizes-stablecoin-rule-with-narrow-payment-of-interest-prohibition/)). Stablecoin Insider's full analysis of the [OCC GENIUS Act final rule](https://stablecoininsider.org/occ-genius-act-final-rule/) covers the proposal versus final changes line by line. ### The rule clock | Milestone | Date | Days from GENIUS Act signing | Source | | ----------------------------------------- | ----------- | ---------------------------- | -------------------------------------------------------------------------------- | | GENIUS Act becomes law | 18 Jul 2025 | 0 | [TokenPost](https://www.tokenpost.com/news/regulation/35111) | | OCC proposed rule | 25 Feb 2026 | 222 | [TokenPost](https://www.tokenpost.com/news/regulation/35111) | | Gould: final rule by November | 19 Aug 2026 | 397 | [OCC](https://www.occ.gov/news-issuances/news-releases/2026/nr-occ-2026-69.html) | | Gould: final rule "in the very near term" | 15 Oct 2026 | 454 | [TokenPost](https://www.tokenpost.com/news/regulation/35111) | | Final rule announced | 21 Oct 2026 | 460 | [OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html) | | Rule and Act take effect | 18 Jan 2027 | 549 | [OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html) | Day counts are Stablecoin Insider calculations. The OCC beat Gould's own August target of November, and as of 27 October 2026 there are 83 days left before the effective date. The agency says it will announce separately when it starts accepting issuer applications and waiver requests ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). ## The questions Jonathan Gould faces The most visible test of his tenure has been World Liberty. The OCC granted preliminary conditional approval to World Liberty Trust Company on 14 August 2026, an applicant CNBC described as Trump family-backed, and CNBC reported the conflict questions raised about the review ([CNBC](https://www.cnbc.com/2026/08/14/world-liberty-trump-occ-bank-charter-stablecoin.html)). The OCC said career staff made the decision ([OCC letter](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf)). Stablecoin Insider covered the [World Liberty trust bank approval](https://stablecoininsider.org/occ-approves-world-liberty-trust-bank-usd1/) in August. The second debate is about yield and bank deposits. ABA President and CEO Rob Nichols said the final rule "will preserve the status quo for crypto platforms despite Congress's clear intent to protect local lending" ([ABA Banking Journal](https://bankingjournal.aba.com/2026/10/occ-finalizes-stablecoin-rule-with-narrow-payment-of-interest-prohibition/)). The third is speed. Fast charters help new entrants, but they also put more weight on supervision after opening, which is where the final rule moved much of its judgment. What Stablecoin Insider doesn't know: how many of the 23 digital asset applications are stablecoin issuers, when the OCC will open the GENIUS Act application window, and how examiners will apply the case by case yield test in practice. No regulator or court has made a finding of wrongdoing against Gould. 📌 Scope note: this profile relies on OCC releases, approval letters and the final rule, plus named reporting from ABA Banking Journal, CNBC and TokenPost. Quotes are reproduced as published. Stablecoin Insider has not interviewed Gould or the OCC. ## What Gould's OCC means for stablecoin issuers - Expect a charter route, not a carve-out. The OCC is treating stablecoin activity as part of the business of banking, so issuers should plan for national trust or bank structures. - Budget capital above the floor. In the Circle, Ripple and World Liberty letters, tier 1 requirements run from 1.21 to 4 times the $5 million rule minimum. - Plan for months, not weeks. Conditional to final approval took 210 to 318 days for the first two issuer trust banks. - Prepare for examiner judgment. Looser hard ratios in the final rule mean stress tests and reserve buffers carry more weight in supervision. If you are preparing a filing, Stablecoin Insider's step by step guide on [how to apply for OCC stablecoin issuer approval](https://stablecoininsider.org/how-to-apply-for-occ-stablecoin-issuer-approval/) walks through the process from the rule text. For a full-service bank comparison, see the [Revolut OCC conditional approval](https://stablecoininsider.org/revolut-occ-conditional-approval-us-bank-stablecoin/), where the bank's stablecoin role is limited to marketing, access and custody. [Read the OCC stablecoin application guide](https://stablecoininsider.org/how-to-apply-for-occ-stablecoin-issuer-approval/) [OCC GENIUS Act Final Rule: Yield, Reserves and RedemptionsWhat survived from the OCC's March proposal: the yield presumption, daily liquidity, capital floors and the application timeline.![](https://stablecoininsider.org/favicon.ico)Stablecoin Insider](https://stablecoininsider.org/occ-genius-act-final-rule/) --- ## FAQ: Jonathan Gould #### Who is Jonathan Gould? Jonathan V. Gould is the 32nd Comptroller of the Currency and head of the OCC, the federal regulator of national banks and national trust banks. He was sworn in on 15 July 2025 ([OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-70.html)). #### Did Jonathan Gould work in crypto before the OCC? Yes. He joined blockchain firm Bitfury as chief legal officer in February 2022 before becoming a partner at Jones Day that September ([Wikipedia](https://en.wikipedia.org/wiki/Jonathan%5FGould%5F%28lawyer%29)). #### What did Gould's OCC decide on stablecoins in October 2026? The OCC announced its GENIUS Act final rule on 21 October 2026, effective 18 January 2027, and Ripple National Trust Bank received final approval on 26 October ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html); [Ripple](https://ripple.com/ripple-press/ripple-receives-final-occ-approval-to-establish-national-trust-bank/)). #### Which stablecoin issuers have OCC trust bank approvals? Circle and Ripple have final approval. World Liberty holds preliminary conditional approval, and BitGo, Fidelity Digital Assets and Paxos received conditional approval in December 2025 to convert to national trust banks ([OCC](https://www.occ.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html); [OCC letter](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf)). #### When can stablecoin issuers apply to the OCC under the GENIUS Act? The OCC says it will announce in a separate release when it begins accepting applications and waiver requests; the final rule and the GENIUS Act take effect on 18 January 2027 ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). ## What to watch next - The OCC release that opens the GENIUS Act application and waiver window ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). - The separate Treasury and OCC anti-money laundering and sanctions rule for issuers ([OCC](https://occ.gov/news-issuances/news-releases/2026/nr-occ-2026-92.html)). - Whether World Liberty moves from preliminary conditional to final approval ([OCC letter](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1385.pdf)). This content is provided for informational and educational purposes only and does not constitute financial, investment, legal or tax advice. Regulatory timelines, charter conditions and rule text can change, so check the OCC's current publications before relying on any date or figure here. Criticism described in this profile is attributed to its sources and is not a finding of wrongdoing. No material herein should be interpreted as a recommendation, endorsement, or solicitation to buy or sell.