A conditional charter for the president's stablecoin, with Circle and Coinbase in the same queue

The look-through arithmetic is worth doing by hand. Trump's 38 percent of World Liberty Financial is held through DT Marks DeFi, an entity in which he owns 70 percent ^[4], which puts his economic interest at roughly 27 percent ^[1]. Aryam Investment, tied to the Abu Dhabi royal family, holds 49 percent as a financial investor, and the family of Middle East envoy Steve Witkoff holds the rest ^[5], about 13 percent ^[2]. The largest single economic holder of the firm that just cleared conditional approval is a Gulf-linked investor; the president's interest is second.

That ownership table is the underwriting problem for the other names. Bloomberg placed World Liberty in the same set of likely entrants as Circle, Nu Holdings and Coinbase ^[2]. None of those three chose their queue-mates, and none of them can hedge the thing that makes the queue contestable: critics have called World Liberty's application brazen self-dealing, on the argument that the president appoints the regulator reviewing his family's business ^[13], and Todd Baker of Columbia's Richman Center says the OCC is overstepping its authority, pointing to the revision of trust charter rules ^[12]. A charter granted under a standard someone is arguing was set improperly is a charter with a tail.

The scrutiny question is not rhetorical. Morningstar's account of what World Liberty still has to do runs to four items: pass a final OCC examination, complete capital funding, build internal control systems, and have its reserve management framework verified ^[3]. Under Comptroller Jonathan Gould, the OCC answers charter applications within 120 days, against reviews that used to take years ^[8]. Gould told Congress in June that the agency is "open for business again" ^[9], and the volume matches the slogan: 22 approvals in the first 19 months of the second term, more than the previous five years combined ^[6], or about 1.2 a month ^[3], with roughly 40 applications filed since early last year, comparable to the prior 13 years of applicants ^[7].

What the charter buys is spelled out in the company's own reasoning. Holding the assets backing USD1 inside its own bank cuts costs, lets it sell crypto services directly, adds stability, and in a crisis opens a path to cheap funding or a government bailout ^[10]. That last item is the one Aaron Klein of Brookings is describing when he says the real concern is the illusion that stablecoins carry a government guarantee, since they are not covered by deposit insurance ^[11]. The charter's value depends partly on a backstop that the product does not have.

Sequencing sharpens it. A February 2025 executive order requires new financial regulations to pass White House review before release, which Maxine Waters, ranking Democrat on House Financial Services, objected to on the grounds that the president would see rule changes first ^[15]. Whoever prices charter optionality at Circle or Coinbase is pricing that review chain too.