rewrite this title JPMorgan just crossed a dangerous line with Solana that major banks have strictly avoided until now

JPMorgan recently issued $50 million in US commercial paper for Galaxy Digital on Solana, with Coinbase and Franklin Templeton as buyers.

The bank created an on-chain USCP token, settling both issuance and redemption cash flows in USDC rather than bank wires. Both issuance and servicing of the deal ran entirely on blockchain rails.

As a template, JPMorgan intends to extend to more issuers, investors, and security types in 2026.The announcement follows a pattern. Institutional on-chain issuance headlines recur every few months, such as Siemens’ €300 million digital bond, Goldman Sachs and BNY Mellon’s tokenized money market funds, and BlackRock’s BUIDL crossing $2.85 billion for the first time.

Each is presented as a breakthrough. The challenge is separating structural progress from proof-of-concept theater. The value is in tracing what actually happened: asset type, settlement finality, counterparties, permissions, and whether the design choices change future issuance behavior or remain confined to one-off pilots.

Where the JPMorgan/Solana deal actually sits

JPMorgan has run tokenized debt experiments before, but on private infrastructure. In April 2024, the bank facilitated a municipal securities offering for the City of Quincy on its permissioned platform. It issued commercial paper for OCBC on its proprietary distributed ledger.

The Solana trade is not the first tokenized debt deal, but it is the first time JPMorgan’s stack crosses into a public chain with real-world corporate paper, a brand-name issuer, and buyers who also operate in the crypto ecosystem.

The shift from permissioned to public infrastructure matters because it changes who can participate and how assets move.

Permissioned platforms limit access to pre-approved entities and keep settlement inside a controlled environment. Public chains expose tokenized assets to broader liquidity, composability with other on-chain instruments, and integration into crypto-native collateral and lending protocols.

The JPMorgan deal deliberately crosses that line, settling in USDC on Solana rather than in bank deposits on a private ledger.

R3’s partnership with the Solana Foundation reinforces the trend. R3’s Corda platform already supports roughly $10 billion in tokenized assets for clients, including Euroclear, HSBC, and Bank of America.

Integrating Solana as a public chain option for tokenized shares and funds signals that institutions are treating public blockchains as production infrastructure, not just sandbox environments.

The 2024/25 tokenized debt and cash landscape

Tokenized Treasury and money market funds reached approximately $7.4 billion by July 2025, up roughly 80% year-to-date, driven by BlackRock, Franklin Templeton, and Janus Henderson’s Anemoy products.

These tokens increasingly function as collateral in crypto derivatives and lending, not just as yield-bearing cash parking. Data from rwa.xyz shows tokenized Treasuries surpassed $9 billion in 2025, with BlackRock’s BUIDL alone reaching $1 billion in total value locked mid-year and growing to approximately $2.85 billion by October.

Additionally, Circle’s USYC recently surpassed $1 billion in assets, fueled by its partnership with Binance to use tokenized fund shares as collateral for trading.

Most of that growth sits in funds and collateral tokens that live inside walled gardens.

BUIDL is limited to qualified institutions and is mainly used as collateral on institutional or large crypto venues. Franklin’s BENJI fund is registered under the 1940 Act and allows investors to fund with USDC, but the fund’s shares remain constrained by mutual-fund rules.

Goldman and BNY Mellon’s tokenized MMF work allows institutions to subscribe and redeem via tokenized rails, while keeping the official record and most settlement in traditional infrastructure.

The JPMorgan/Galaxy commercial paper deal sits at a different intersection: a mainstream corporate borrower issuing on a public chain, settling into a crypto-native dollar instrument, with investors spanning both traditional finance and digital-asset platforms.

That combination is rare enough to warrant scrutiny.

Separating headline PR from real progress

Reading tokenized issuance announcements requires a repeatable evaluation framework.Five questions reveal whether a deal changes market structure or remains a one-off experiment.

First, what is the asset? Is the blockchain token the legal security itself, or just a representation?

Siemens’ €300 million bond is issued natively as a digital security with no paper certificate. The JPMorgan/Galaxy commercial paper is conventional CP from a legal standpoint, but with its lifecycle events of issuance, servicing, and eventual redemption mirrored on Solana through the USCP token.

The distinction determines whether the blockchain record is authoritative or auxiliary.

Second, how does the cash leg settle, and where is finality? Most of the experiments in 2024 and 2025 settle either in central bank money on a permissioned ledger or in fiat via traditional rails.

The JPMorgan/Solana deal is one of the first in which issuance and redemption settle into a crypto-native dollar instrument (USDC) on a public chain for a mainstream corporate borrower.

That creates settlement finality on-chain rather than relying on off-chain payment confirmation.

Third, who is allowed to hold and move the asset? The $7.4 billion in tokenized Treasury and MMF products is held by professional or crypto-savvy investors, with limited mainstream distribution.

BUIDL is restricted to qualified institutions. Franklin’s BENJI fund is a 1940 Act-registered fund, but mutual fund rules still constrain it. The permission structure determines whether the token can flow freely or remains gated by investor accreditation, KYC, or platform restrictions.

Fourth, can the token be reused as collateral, and does DLT solve a real pain point?

JPMorgan’s Tokenized Collateral Network has demonstrated the use of tokenized money market fund shares as on-chain collateral, with benefits including near-instant repo settlement, atomic delivery-versus-payment, and improved collateral mobilization across fragmented silos.

IOSCO’s 2025 tokenization report notes that only a small number of tokenized MMFs have been used as collateral for crypto transactions to date, specifically citing BUIDL as one example.

The question is whether the token unlocks new collateral velocity or replicates existing workflows on a different infrastructure.

Fifth, does the deal connect to enabling policy changes, or does it rely on regulatory forbearance?

In late 2025, the OCC issued Interpretive Letter 1188, confirming that national banks may engage in “riskless principal” crypto transactions as part of their banking business.

Interpretive Letter 1186 clarified that banks can hold native tokens such as ETH or SOL on their balance sheets to pay network fees and test blockchain platforms.

In January 2025, the SEC rescinded Staff Accounting Bulletin 121, which had forced banks to treat custodied crypto as a balance-sheet liability.

That regulatory combination makes it plausible that a major bank uses public chains and tokenized MMFs or Treasuries as collateral and settlement assets in production, rather than confining experiments to permissioned environments.

CaseAsset & sizePlatform / chainAccess modelWhat’s genuinely newKey limitsJPMorgan – Galaxy Digital USCP on Solana$50m U.S. commercial paperSolana public chainGalaxy as issuer; Coinbase and Franklin as investors; USDC for issuance and redemptionPrimary issuance and servicing of a real CP note on a public L1 with stablecoin cash legLimited to a small, curated investor set; still structured as traditional CP from a legal perspectiveJPMorgan – OCBC commercial paperU.S. commercial paper program (size not public in Reuters but framed as programmatic)JPMorgan’s permissioned DLT and KinexysBank and OCBC clientsNear-real-time settlement of CP on a private DLT; integrated with JPMorgan’s Tokenized Collateral NetworkStays in permissioned environment; no direct public-chain interaction yetSiemens digital bond€300m 1-year bondSWIAT permissioned blockchain with Bundesbank “trigger solution”Institutional investors via dealer banksFull digital issuance and DvP settlement in central-bank money within hours; no paper certificate at allTrading and access still restricted to traditional institutions; ledger is closed rather than publicBlackRock BUIDLTokenized U.S. Treasury fund, multi-billion $ AUMEthereum and other chains, institutional onlyAccredited / institutional holders; a16z and RWA trackers show it as one of the largest tokenized fundsShares are on-chain, accrue yield, and are increasingly used as collateral on crypto venues andtokenized-collateral networks; IOSCO and GFMA cite BUIDL as an example of tokenized MMFs used as collateral–Franklin OnChain U.S. Government Money Fund (FOBXX / BENJI)Regulated 1940-Act government MMF, NAV $1Stellar (and other rails for record-keeping), with USDC on-rampUS and some institutional wallets via Benji; users can fund with USDC via Zero HashFirst US-registered mutual fund to use a public blockchain as system of record; investors can fund via USDC,receive BENJI tokens, and Franklin has enabled peer-to-peer transfers of BENJI on-chainStill a traditional MMF legally; retail reach limited to approved jurisdictions; not freely circulating asDeFi collateralGoldman Sachs / BNY Mellon LiquidityDirectTokenized money-market funds for large clientsGS DAP private blockchain linked to BNY LiquidityDirectInstitutional clients subscribe and redeem MMFs through BNY; BlackRock, Fidelity, Dreyfus, Federated HermesparticipateConnects a major MMF distribution platform to a tokenization layer; total tokenized Treasuries, bonds andcash equivalents put near $6.75b, with BUIDL about one-third of thatTokens do not yet freely trade or plug into open DeFi; they are “mirror” tokens in a tightly controlledenvironment

Applying the framework to the JPMorgan deal

The JPMorgan/Galaxy commercial paper scores as follows: the asset is conventional CP with on-chain lifecycle mirroring, not a native digital security.

Settlement finality in USDC on Solana removes reliance on bank wires but introduces a dependency on the stablecoin issuer. Counterparties include Galaxy Digital as issuer and Coinbase and Franklin Templeton as buyers, all entities with both traditional finance and crypto infrastructure.

The token’s permission structure is unclear from public reporting. Whether it is freely transferable on Solana or restricted to authorized holders determines whether it can flow into broader DeFi protocols or remains a closed loop.

The deal’s collateral reuse potential depends on whether the USCP token can be posted as margin or used in on-chain lending. JPMorgan’s existing Tokenized Collateral Network suggests the bank is building toward that capability, but the Solana CP issuance does not yet demonstrate it.

The policy backdrop is supportive: OCC guidance now permits banks to intermediate crypto transactions and hold gas tokens, and the SEC’s SAB 121 rescission removes a custody accounting barrier.

That makes the Solana deal less of a regulatory stretch than it would have been in 2024.

What actually changes in 2026

The recurring headlines about institutional tokenization create a pattern-recognition problem.

Each announcement is framed as transformative, but most remain confined to proof-of-concept scale, permissioned platforms, or asset classes that already have deep traditional infrastructure.

The JPMorgan/Solana deal crosses into public chain territory with a recognizable corporate issuer and USDC settlement, but the commercial paper market is already highly liquid and efficient.

The question is not whether tokenization is technically feasible, but whether it changes issuance behavior.

The 2026 test is whether tokenized debt and cash instruments start displacing traditional workflows at scale.

That requires four conditions: regulatory clarity on custody and settlement finality, interoperability standards that allow tokens to move across platforms without fragmentation.

Additionally, it needs sufficient liquidity in on-chain venues to compete with traditional order books, and a demonstrated collateral-velocity advantage that justifies the operational overhead of running dual infrastructure.

The OCC and SEC moves in 2025 address the first condition. R3’s Solana integration and JPMorgan’s public-chain expansion suggest progress on the second. The third and fourth remain open questions.

Tokenized Treasuries at nearly $9 billion represent a rounding error in the $28 trillion Treasury market.

BUIDL’s $1.8 billion is meaningful in crypto terms but negligible in global money markets.

The tokenized instruments need to prove they are not just another wrapper product, but a genuinely superior collateral and settlement stack.

JPMorgan’s explicit intention to extend the Solana template to more issuers, investors, and security types in 2026 suggests the bank views the deal as infrastructure building, not PR.

Whether that proves accurate depends on adoption beyond the initial cohort of crypto-native investors and whether the tokens can be reused as collateral in production lending and derivatives markets.

The framework outlined above provides a way to evaluate each subsequent announcement against those criteria, separating structural progress from one-off experiments that generate headlines but do not change market behavior.