Fed Regulation, BNY, Moonpay and more

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Welcome to Global Custody Pro, read by custody professionals like you. I'm Brennan McDonald, Managing Editor. I write about the global custody industry, having spent over 12 years in financial services, including working at a global custody bank. An AI voice reads the audio version of this newsletter. Reply to this email with feedback or connect with us on LinkedIn.

Table of Contents

• 🌏 Global Custody News

  • Fed Overhauls Bank Capital and Supervision Framewo …

• 🚀 Digital Asset News

  • MoonPay Secures New York Trust Charter

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🌏 Global Custody News

Fed Overhauls Bank Capital and Supervision Framework

Federal Reserve Vice Chair for Supervision Michelle W. Bowman told Congress on 2 December that the central bank is modernising its regulatory framework for banks of all sizes, including modifications to stress testing, the supplementary leverage ratio, Basel III implementation, and the G-SIB surcharge for large institutions. Bowman stated the banking system remains sound and resilient with strong capital ratios, significant liquidity buffers, and declining non-performing loans across most categories, though non-bank financial institutions continue to increase their market share without facing equivalent prudential standards.

The Fed recently proposed enhanced transparency for stress testing including public disclosure of models and scenario frameworks, and finalised changes to the enhanced supplementary leverage ratio for U.S. G-SIBs to ensure leverage requirements serve as a backstop rather than binding constraint. Bowman emphasised the need to address mortgage capital treatment under the U.S. standardised approach, noting current requirements have resulted in banks reducing participation in mortgage lending. For community banks, the agency proposed changes to the community bank leverage ratio and released new capital options for mutual banks, whilst supporting Congressional efforts to increase statutory asset thresholds that have not been updated for inflation.

The Fed officially ended the use of reputational risk in bank supervision and is considering regulations to prevent personnel from encouraging banks to refuse service to customers based on constitutionally protected political or religious beliefs. Bowman stated the agency is developing capital, liquidity, and diversification regulations for stablecoin issuers as required by the GENIUS Act and working to provide clarity on digital asset treatment. The Fed is also reviewing its CAMELS ratings framework, which has been in place since 1979 with minimal modification, and recently finalised revisions to the Large Financial Institution ratings system.

Interesting Podcast Episode with BNY’s Leigh-Ann Russell

This was an interesting insight into how a global custody bank is thinking about and implementing AI in a regulated environment. Well worth a listen.

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🚀 Digital Asset News

MoonPay Secures New York Trust Charter

MoonPay announced on 25 November 2025 that the New York State Department of Financial Services has authorised MoonPay Trust Company, LLC as a New York Limited Purpose Trust Company. The approval enables MoonPay to provide digital asset custody and over-the-counter trading services under one of the world's most respected regulatory frameworks.

The trust charter approval builds on MoonPay's BitLicense, which the company secured from the NYDFS in June 2025 and permits operations in all 50 U.S. states. MoonPay also holds registrations in the UK, Australia, Canada, Italy, Ireland, and Jersey, as well as a crypto asset service provider licence under the European Union's Markets in Crypto Assets regulation. "Receiving our New York Trust Charter reflects our commitment to meeting the highest standards of compliance, security, and governance," said Ivan Soto-Wright, co-founder and CEO of MoonPay.

With the new authorisation, MoonPay joins a select group of digital asset companies that have obtained both New York credentials, including Coinbase, PayPal, Ripple, and NYDIG. The company stated the milestone supports its mission to deliver secure, compliant, and scalable financial infrastructure for institutional and enterprise partners.

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