As Inauguration Day rolls around the US, the first political domino to topple may be the industry’s banking roadblocks, though the White House might be the wrong place to look for the most consequential actions.

The crypto industry will surely cheer loudly for some of the executive fireworks when President-elect Donald Trump is sworn in, which could reportedly include directives on crypto, but such orders may be more smoke than fire. (After all, President Joe Biden issued a crypto executive order in 2022 directing the federal government to get a better grip on crypto.)

While the White House highlights its vision for the direction of crypto policy, the concrete steps will be taken at the regulatory agencies, such as the Securities and Exchange Commission and the Federal Deposit Insurance Corp. These are nominally independent regulators, but they want new leadership closely aligned with Trump’s view, even if there is a delay in confirming the permanent agency heads.

At the SEC, former Commissioner Paul Atkins is on deck to receive his formal nomination to take over. But the conservative SEC veteran could be stuck in the middle of the potential bottleneck of Senate confirmations, where the most urgent appointees, such as the new Treasury secretary, will be first in line.

On Jan. 21, the day after inauguration, the commission will have just three members — two Republicans and one Democrat. Trump will be able to appoint one of the two incumbent Republicans as acting chairman, just as Biden had appointed Allison Herren Lee to that role on January 21, 2021 at the beginning of his presidency. Both Republican commissioners, Mark Uyeda and Hester Peirce, once served Atkins as his SEC counsel, so they’re likely to be on the same side as him anyway.

Some expect Commissioner Uyeda to get the nod to be acting chairman, and there is one change he could immediately make that would have massive implications for cryptobanking. He has said that he is in favor of deleting the controversial personnel accounting bulletin no. 121 (SAB 121), effectively requiring banks to treat their customers’ cryptoassets as their own, accounting for tokens on their balance sheets, and taking the resulting hit to the capital they need to expensively maintain. A hypothetical acting Chairman Uyeda could direct that the bulletin be withdrawn, removing enforcement pressure from the big banks that have had to step lightly into crypto matters.

Commissioner Peirce also openly opposed SAB 121 from within the agency, issuing a statement asserting, “SAB does not recognize the Commission’s own role in creating the legal and regulatory risks that justify this accounting treatment.” So if she were to take over, the bulletin could similarly be scrapped.

SAB 121 has been under the gun since it was issued, and Congress rose last year to strike it from the books in a broad, bipartisan vote to use the Congressional Review Act to reverse the SEC action. But President Biden bent his veto to protect the accounting standard.

In a public statement in September, the SEC’s chief accounting officer, Paul Munter, held the line on SAB 121, saying his accounting staff still felt the same way a bank’s balance sheet should “reflect its commitment to protect the crypto assets held for others.” But the agency announced Tuesday that he would retire next week. The overhauled agency gets a new accounting manager.

If the bench waits for Atkins to arrive, the former commissioner himself is expected to scrap SAB 121. When his name surfaced last month as Trump’s SEC pick, Rep. Mike Flood, a Nebraska Republican who led the House charge, wrote against the accounting standard, on the social media X that he looked forward to “working with him to finish SAB 121.”

Meanwhile, US banking regulators could quickly issue orders to their teams of banking supervisors that crypto should no longer be shielded. At the FDIC, longtime chairman Martin Gruenberg is expected to leave the day before the inauguration. That puts Republican Vice Chairman Travis Hill in charge, at least in an interim capacity.

“We expect Hill to put forward a proposal that both clarifies that banks can engage in crypto activities and specifies when regulators must first approve an activity,” Jaret Seiberg, a fiscal policy analyst at TD Cowen, said in a note to clients. “It will also likely include strict deadlines for the FDIC to act.”

Last week, Hill outlined several pro-crypto policy thoughts, arguing that the agency “stifled innovation and contributed to a public perception that the FDIC is closed to business if institutions are interested in anything related to blockchain or distributed ledger technology.” ” He also argued that the FDIC had launched an inappropriate campaign to sever banking ties for crypto firms and those involved in them.

“I continue to believe that a much better approach would have been — and remains — for the agencies to clearly and transparently describe to the public what activities are legally permissible and how they are conducted in accordance with safety and soundness standards,” Hill said. “And if there is a need for regulatory approvals, they must be acted upon in a timely manner, which has not been the case in recent years.”

Read more: US banks should ease the way for crypto, Republican takes reins at FDIC suggests

The FDIC’s restrictions on banks’ involvement in crypto are not in the form of regulations, but of guidance that can be more easily audited. However, there are two other agencies that share the duties of regulating US banks: the Office of the Comptroller (OCC) of the Currency and the Federal Reserve.

The OCC has actually been run by an acting administrator, Michael Hsu, for more than three years. Hsu has said he is awaiting the new election to replace him, which is as simple as the president instructing his Treasury secretary to appoint a “first deputy comptroller,” a designation that automatically puts that person in the role of acting comptroller under the OCC- the rules. Trump had once installed Brian Brooks in the acting duty, where Brooks – a former executive at Coinbase and other crypto companies – quickly moved to blast an entry into the banking system for crypto companies, including through a new approach to charters.

At the Fed, the board’s vice chairman for supervision, Michael Barr, said he will step down at the end of February. Barr had been in that role when the Fed issued warnings to the banks it oversees that any crypto activity would need to be carefully managed by the regulator before the institutions could move forward. His departure potentially leaves an opening for a future deputy chairman who wants to encourage lenders to get into digital assets.

With the old guard heading for the exits at the SEC and the banking agencies, some of the key restrictions on cryptobanks are particularly vulnerable.

However, Seiberg had added a bit of Washington wisdom to his note: “Our caution — with a tip of the hat to Mike Tyson — is that everyone has a plan until they get punched in the face.”