Eleven companies filed for or received Office of the Comptroller of the Currency (OCC) national trust bank charters within 83 days between December 2025 and March 2026 — the largest wave of crypto-related federal banking applications in U.S. history. Simultaneously, at least four of the six large...
"These companies are effectively crypto banks that want to evade the fundamental safeguards and obligations that come with being a bank." — Senator Elizabeth Warren, Ranking Member, Senate Banking Committee
Eleven companies filed for or received Office of the Comptroller of the Currency (OCC) national trust bank charters within 83 days between December 2025 and March 2026 — the largest wave of crypto-related federal banking applications in U.S. history. Simultaneously, at least four of the six largest U.S. and European banks — Citigroup, Goldman Sachs, Morgan Stanley, and Deutsche Bank — launched or expanded crypto custody, trading, and tokenization operations through 2026. The result is a two-directional convergence: crypto-native firms acquiring bank charters, and incumbent banks acquiring crypto capabilities.
Erebor Bank, the first de novo national bank charter granted under the current administration, saw deposits quadruple from $1.1 billion to $4.05 billion in three months (Q1–Q2 2026) and is negotiating a $1.5 billion funding round at a $9.5 billion valuation. Circle received final OCC approval on July 10, 2026, to operate First National Digital Currency Bank, N.A. On the other side of the convergence, Citi is building institutional-grade Bitcoin custody, and Goldman Sachs holds approximately $1.6 billion in Bitcoin ETFs.
The regulatory architecture enabling this convergence rests on a single OCC rule change effective April 1, 2026, which broadened national trust bank authority from "fiduciary activities" to "operations of a trust company and activities related thereto." This amendment removed ambiguity about whether federally chartered trust banks can hold assets in non-fiduciary custody — a function essential to crypto operations. Senator Warren has challenged the legality of these approvals, accusing the OCC of allowing crypto firms to function as banks without meeting traditional banking safeguards.
On December 12, 2025, the OCC granted conditional approval to five national trust bank charter applications simultaneously: First National Digital Currency Bank (Circle), Ripple National Trust Bank, BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company. Two were de novo charters; three were conversions from state trust companies. According to Cadwalader, Wickersham & Taft's analysis of the approvals, this represented the first expansion of federal crypto banking since Anchorage Digital received its charter in January 2021.
Three more conditional approvals followed in February 2026: Protego, Bridge (Stripe's stablecoin subsidiary acquired for $1.1 billion in 2024), and Crypto.com. By March 2026, six additional applications had been filed, bringing the total to 11 firms in 83 days. The applicants included Morgan Stanley, Payoneer, and Zerohash, according to reporting by FinTech Weekly.
Coinbase and World Liberty Financial have applications pending as of August 2026.
The timeline of final approvals has been slower. As of August 13, 2026, only two firms have received final OCC sign-off:
| Firm | Charter Type | Conditional | Final | |------|-------------|-------------|-------| | Anchorage Digital | National Trust | 2021 | 2021 | | Erebor Bank | De Novo National | Oct 2025 | Feb 2026 | | Circle (FNDCB) | National Trust | Dec 2025 | Jul 2026 | | Ripple | National Trust | Dec 2025 | Pending | | BitGo | National Trust | Dec 2025 | Pending | | Fidelity Digital | National Trust | Dec 2025 | Pending | | Paxos | National Trust | Dec 2025 | Pending | | Protego | National Trust | Feb 2026 | Pending | | Bridge (Stripe) | National Trust | Feb 2026 | Pending | | Crypto.com | National Trust | Feb 2026 | Pending |
The mechanism behind the charter rush was a single regulatory amendment to 12 CFR 5.20, effective April 1, 2026. The OCC replaced the phrase "fiduciary activities" with "operations of a trust company and activities related thereto" in the definition of what national trust banks can do.
The practical effect: national trust banks can now hold digital assets in non-fiduciary custody accounts — meaning a crypto custodian need not act as a fiduciary to every client to qualify for a federal charter. For stablecoin issuers like Circle and Paxos, this means reserve assets can be held under direct federal supervision without the ambiguity that previously surrounded their state-level trust structures.
According to Davis Wright Tremaine's analysis published in August 2026, the rule change "signals momentum for digital-asset bank charters" and aligns OCC interpretation with the practical realities of crypto custody, where assets are held under contractual — not necessarily fiduciary — terms.
Erebor Bank, headquartered in Columbus, Ohio, represents the most aggressive test of whether a newly chartered bank can bridge traditional commercial banking with stablecoin-enabled infrastructure. Founded by Palmer Luckey and backed by Peter Thiel's Founders Fund, 8VC, and Haun Ventures, Erebor launched on February 8, 2026, with $625 million in initial capital.
The deposit trajectory has been steep. According to Dealroom and Bloomberg reporting from July 2026:
Luckey stated publicly that none of the deposit growth in Q2 came from companies he is personally affiliated with. Erebor targets companies in defense technology, AI, crypto, and advanced manufacturing — sectors that, according to the bank, have historically been underserved by traditional lenders due to compliance costs and reputational concerns.
Erebor raised $350 million at a $4.35 billion valuation in late 2025, led by Lux Capital. By August 2026, per Financial Times reporting, the bank was negotiating a $1.5 billion round at a $9.5 billion valuation — a 118% increase in implied value within approximately eight months. Erebor expects to reach profitability by year-end 2026.
The bank is FDIC-insured, operates as a branchless 24/7 institution, and is building stablecoin payment rails into its core banking stack. It holds a full national bank charter — not a trust charter — giving it broader powers than the 11 trust-charter applicants, including the ability to accept demand deposits.
The convergence is not unidirectional. Major banks are building crypto capabilities from the other side:
Citigroup announced plans in October 2025 to launch institutional crypto custody by 2026. Nisha Surendran, who leads Citi's digital asset custody buildout, described the effort as making "bitcoin bankable" through institutional-grade key management and wallet infrastructure. The service targets custody of assets backing stablecoins — primarily U.S. Treasuries and cash — and crypto ETFs. Citi's advantage, according to the bank, is its ability to serve as a single platform for both traditional and digital assets.
Goldman Sachs holds approximately $1.6 billion in Bitcoin ETFs according to recent filings, has relaunched its crypto trading desk focused on Bitcoin derivatives, and is expanding integration with crypto exchanges for institutional clients.
Morgan Stanley filed for an OCC national trust bank charter in the 83-day wave — making it the only top-six U.S. bank to seek dedicated federal crypto infrastructure alongside the crypto-native applicants.
Deutsche Bank is building crypto custody through partnerships with Bitpanda Technology Solutions and Swiss firm Taurus SA, with launch planned for 2026. Deutsche Bank invested in Taurus's $65 million funding round in 2023.
According to a 2026 survey cited by Bitcoin Foundation, 60% of the top 25 U.S. banks now offer some form of cryptocurrency service, including custody, trading, or lending backed by digital assets.
The economics driving both sides of this convergence are structural:
For crypto-native firms, a federal charter provides access to the Federal Reserve's payment systems, FDIC insurance eligibility (for full bank charters like Erebor), and regulatory credibility with institutional counterparties. The cost is compliance with OCC examination, capital adequacy requirements, and Bank Secrecy Act/Anti-Money Laundering obligations.
For incumbent banks, crypto custody and tokenization represent fee revenue from a growing asset class without balance-sheet risk. Citigroup has estimated that tokenized securities could reach $5.5 trillion by 2030, including $2.6 trillion in tokenized equities. Custody fees on digital assets currently range from 10 to 50 basis points annually — higher than traditional securities custody.
The repeal of SEC Staff Accounting Bulletin 121 (SAB 121) in early 2025 removed a significant obstacle: under SAB 121, banks that custodied crypto were required to record client crypto assets as liabilities on their own balance sheets, making the business economically unviable. With that rule rescinded, banks can hold client crypto off-balance-sheet, consistent with traditional custody accounting.
The fee arbitrage is visible. Erebor's rapid deposit growth suggests pent-up demand from technology companies that found traditional banks unwilling to serve them. Conversely, Citi and Goldman are capturing institutional demand from clients who want crypto exposure through existing banking relationships rather than new counterparties.
The charter expansion has not proceeded without opposition. Senator Elizabeth Warren sent OCC Comptroller Jonathan Gould a formal letter on May 18, 2026, targeting nine crypto trust charters, including those granted to Coinbase and Ripple affiliates.
Warren's core argument: the applicants are conducting activities — trading, payments, lending, stablecoin issuance — that exceed what national trust banks traditionally do, effectively functioning as full-service banks without meeting full-service bank requirements. Warren set a June 1, 2026, deadline for the OCC to produce charter records and any communications related to the Trump family's World Liberty Financial application.
The Clarity Act, which would have provided a comprehensive legislative framework for crypto firm regulation, had its Senate vote postponed to September 2026, leaving the OCC's administrative actions as the de facto regulatory framework.
The legal question is unresolved. If Warren's interpretation prevails in future litigation or legislation, some trust-charter holders could face restrictions on their activities or be required to upgrade to full bank charters — a materially more expensive and time-consuming process.
The U.S. banking system is undergoing a structural merge with the crypto industry — not through legislation, but through administrative action. The OCC's 83-day charter wave and its April 2026 rule change have created a permissive environment for crypto firms to enter the federal banking system, while SAB 121's repeal has removed the last major obstacle for incumbent banks to custody digital assets. The convergence is occurring from both directions simultaneously: crypto firms are becoming banks, and banks are becoming crypto custodians.
Whether this architecture survives depends on two pending events: the Clarity Act vote in September and the resolution of Senator Warren's legal challenge to the OCC's charter authority. Until then, the convergence continues under the OCC's interpretation of a 19th-century banking statute — an interpretation that 11 companies are now betting their regulatory futures on.