On March 5, 2026, the Board of Governors of the Federal Reserve System (“Federal Reserve”), the Office of the Comptroller of the Currency (“OCC”), and the Federal Deposit Insurance Corporation (“FDIC,” collectively, the “Agencies”) issued joint interagency guidance clarifying the regulatory capital treatment of tokenized securities held by banking organizations. (Federal Reserve Press Release (Mar. 5, 2026)). The guidance confirms that tokenized representations of traditional financial instruments, including U.S. Treasury securities and agency mortgage-backed securities, should receive the same risk weight and capital charge under existing regulatory capital frameworks as their conventional, non-tokenized counterparts held in book-entry form. The Agencies concluded that the use of distributed ledger technology (“DLT”) or blockchain to record ownership or facilitate transfers does not, by itself, alter the risk profile of the underlying security.
The guidance adopts a “technology-neutral” approach, consistent with the broader trend across federal financial regulators of evaluating tokenized assets based on their underlying economic substance rather than the form of technology used to represent or transfer them. Under this framework, a tokenized U.S. Treasury bond carries the same credit risk, market risk, and liquidity characteristics as a traditional U.S. Treasury bond, and the capital rules apply accordingly. This approach is consistent with the CFTC’s own tokenized-collateral guidance, which similarly advised market participants to analyze tokenized assets under the same legal, operational, and risk-management standards that apply to their non-tokenized equivalents. (see CFTC Staff Ltr. No. 25-39 (Dec. 8, 2025)).
The Agencies’ guidance is intended to remove key barriers to the broader adoption of tokenization within the regulated banking system, including addressing the uncertainty around how regulators would treat these instruments for purposes of risk-based capital requirements.
The guidance also addresses several related considerations for banking organizations. Institutions are expected to conduct appropriate due diligence on the legal enforceability of ownership rights represented by tokenized securities. Banks must also evaluate the operational and technological risks associated with the DLT platforms on which tokenized securities are issued or transferred, including cybersecurity, custody, and smart contract risk. The Agencies noted that existing supervisory expectations around risk management, internal controls, and third-party vendor oversight continue to apply in full to activities involving tokenized assets. The interagency guidance follows a series of recent actions by federal regulators aimed at establishing a clearer regulatory framework for digital assets and tokenized financial products. On December 8, 2025, CFTC launched a pilot program permitting certain digital assets to serve as collateral in U.S. derivatives markets and issued tokenized-collateral guidance for real-world assets such as U.S. Treasuries and money-market funds. (CFTC Rel. No. 9146-25 (Dec. 8, 2025)). These actions collectively represent a coordinated effort across federal agencies to integrate tokenized and digital assets into the existing U.S. financial regulatory infrastructure while maintaining robust prudential standards. The Agencies indicated that they will continue to monitor developments in the tokenization space and may issue additional guidance as the market evolves.
