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The Hidden Risks For Banks Building Hybrid Payment Flows

The most interesting conversations inside midsize and regional banks right now are not about whether to issue a stablecoin. They are about how to pair stablecoins with tokenized deposits to move customer money faster and at lower cost. Each instrument does something the other cannot, and banks are beginning to design payment flows that use both, such as Anchorage Digital,¹ which has launched both payment solutions. Those payment flows deserve as much supervisory planning as they do engineering.

Start with what separates the two instruments. A tokenized deposit is still a deposit. It stays on the bank’s balance sheet as a liability, it can carry Federal Deposit Insurance Corporation (“FDIC”) insurance, and it can pay yield to the customer. It moves value efficiently within a single institution or among a consortium of banks. A payment stablecoin, the instrument the Office of the Comptroller of the Currency (“OCC”) addresses in its proposed rule² to implement the Guiding and Establishing National Innovation for U.S. Stablecoins Act (final rule expected in late 2026), is a different animal. It is backed by reserves and redeemable at par, its issuer cannot pay yield to holders, and it is not FDIC-insured. What it offers is reach: cross-border movement at low cost and across networks that a closed deposit system cannot reach.

Insured or Not Insured: What Banks Are Telling Customers

Because each instrument is strong where the other is weak, banks are considering hybrid flows that pass value from one instrument to the other. A customer’s funds might begin as a tokenized deposit, convert to a stablecoin for an efficient cross-border leg, then convert back into a deposit at the destination. To the customer, the experience is simply money moving from one place to another.

Inside the flow, something more complicated is happening. For the stretch that the value travels as a stablecoin, FDIC insurance lapses, yield stops, and the customer is exposed to risks that belong to the blockchain itself: a network fork, a smart-contract exploit or a lost key. The amounts and the elapsed time may be small, but the exposure is real. It also raises a question the bank must answer before orchestrating the flow: What must a customer be told about the moment an insured interest-bearing deposit becomes an uninsured token on a public network?

That question is where supervision enters the picture. Examiners will read these flows through the OCC’s risk assessment system³ – the same framework they apply to any activity. The blockchain mechanics and the conversion points are operational risk. Reserve monetization, redemption under stress, and the possibility of a run are liquidity risk. The disclosure duties and consumer-protection obligations are compliance risk. The decision to build the capability is strategic risk.

None of these lenses are new. The activity is novel. The framework that governs it is not.

Aggregating Risks and the Effects on Hybrid Payments

Like any risks, bank leadership teams should focus on what the aggregate risks are. Once a bank is running hybrid payment flows, findings under the risk assessment system become CAMELS ratings and the specialty ratings the OCC assigns alongside them for information technology, trust, and consumer compliance. The components most exposed are liquidity, capital, and management. On the specialty side, this includes information technology and consumer compliance.

The crucial feature of these findings is that they are financial. A redemption spike that outruns reserve monetization is a liquidity strain. A smart-contract failure is an operational loss. A disclosure program that does not keep pace with the product is a remediation cost. These are not quiet supervisory observations. They surface in financial performance.

The timing sharpens the stakes. The Federal Financial Institutions Examination Council has proposed⁴ the first comprehensive revision of the bank rating system since 1996, with comments due in August. The proposal refocuses component and composite ratings on material financial risk and narrows the management component. It would be easy to interpret that change as relief for management teams. For this activity, it is not.

When a hybrid payment flow fails, the cause could be traced to strategic planning and new-activity risk management, which are among the clearest measures of how a management team performs. A rating that concentrates on material financial risk still captures a failure that produces a liquidity run or an operational loss, and it still reflects the judgment that allowed the activity outrun its controls.

How Financial Institutions Keep Up With a Fast-Moving Market

The broader reality is that nothing in this market is standing still. Many stakeholders are moving on innovation at once, and interconnection is growing faster than true interoperability. That gap raises the odds of operational losses and liquidity pressure that cross institutional lines.

Avoiding the activity is not the answer. Sitting it out carries its own strategic risk as competitors take the market that responsible entrants are building. The answer is to innovate with the discipline that regulators already expect. The OCC’s guidance on new, modified or expanded products and services⁵ and its corporate and risk governance⁶ handbook already describe how to take on novel activity prudently, from board oversight to pre-launch risk assessment to ongoing monitoring.

The banks whose ratings hold up through this period will be the ones that treat innovation and prudent risk management as a single strategy rather than competing projects. The guidance to manage stablecoins, tokenized deposits and the flows that connect them already exists. The institutions that use it will be the ones still moving value and protecting their customers when the examiner arrives.

Footnotes:

1: Anchorage Digital, “Anchorage Digital Launches Tokenized Deposit Infrastructure for Banks, Delivering 24/7 Settlement Without Replacing Core Systems,” (June 22, 2026).

2: Office of the Comptroller of the Currency, “Implementing the Guiding and Establishing National Innovation for U.S. Stablecoins Act for the Issuance of Stablecoins by Entities Subject to the Jurisdiction of the Office of the Comptroller of the Currency,” (March 2, 2026).

3: Office of the Comptroller of the Currency, “Bank Supervision Process,” (September 2019).

4: The Federal Register National Archives, “Uniform Financial Institutions Rating System,” (March 19, 2026).

5: Office of the Comptroller of Currency, “New, Modified, or Expanded Bank Products and Services: Risk Management Principles,” (October 20, 2017).

6: Office of the Comptroller of Currency, “Corporate and Risk Governance,” (July 2019).