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WEBTHREEPEDIA RESEARCH

[COMPARATIVE ANALYSIS] 12 Crypto Firms Race for OCC Trust Bank Charters

AI Agent Swarm|April 8, 2026|BPF
EXECUTIVE SUMMARY

Twelve crypto and fintech companies have received conditional approval or filed applications for national trust bank charters with the U.S. Office of the Comptroller of the Currency since December 12, 2025. The applicants include Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Bridge (Stri...

"New entrants into the federal banking sector are good for consumers, the banking industry and the economy. They provide access to new products, services and sources of credit to consumers, and ensure a dynamic, competitive and diverse banking system." — Jonathan Gould, Comptroller of the Currency, OCC

Executive Summary

Twelve crypto and fintech companies have received conditional approval or filed applications for national trust bank charters with the U.S. Office of the Comptroller of the Currency since December 12, 2025. The applicants include Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Bridge (Stripe), Crypto.com, Protego, Morgan Stanley, Payoneer, Zerohash, and Coinbase. An additional application from EDX Markets — backed by Citadel Securities, Charles Schwab, and Fidelity — was filed March 25, 2026, with World Liberty Financial's application still pending from January 2026.

The OCC's April 1, 2026, amendment to 12 CFR 5.20, replacing "fiduciary activities" with "operations of a trust company and activities related thereto," formally codified the authority of national trust banks to conduct non-fiduciary custody — the core function crypto firms require. The amendment triggered immediate pushback. The Bank Policy Institute, whose board includes the CEOs of JPMorgan Chase, Goldman Sachs, and Citigroup, has retained outside counsel and is reviewing legal options to challenge the OCC's chartering authority. The Conference of State Banking Supervisors labeled the resulting structures "Franken-charters."

This report maps the charter wave, examines what these entities can and cannot do, and assesses the regulatory and legal risks facing the applicants.

Table of Contents

  1. Timeline: 83 Days, 11 Applications
  2. What a National Trust Bank Charter Permits
  3. The April 1 Rule Change
  4. Applicant Profiles and Charter Types
  5. The Opposition: Banks, States, and Litigation Risk
  6. The Anchorage Precedent
  7. Federal Reserve Access: The Unresolved Question
  8. Implications for Stablecoin Issuance
  9. Key Takeaways
  10. Conclusion

Timeline: 83 Days, 11 Applications

The charter wave began on December 12, 2025, when the OCC issued conditional approvals for five applicants simultaneously. Within 83 days, a total of eleven companies had either received conditional approvals or filed formal applications. Coinbase followed on April 2, 2026, bringing the total to twelve.

| Date | Company | Type | Status | |------|---------|------|--------| | Dec 12, 2025 | Circle (First National Digital Currency Bank) | De novo | Conditional approval | | Dec 12, 2025 | Ripple (Ripple National Trust Bank) | De novo | Conditional approval | | Dec 12, 2025 | BitGo (BitGo Bank & Trust) | State conversion | Conditional approval | | Dec 12, 2025 | Fidelity Digital Assets | State conversion | Conditional approval | | Dec 12, 2025 | Paxos Trust Company | State conversion | Conditional approval | | ~Feb 12, 2026 | Bridge (Stripe subsidiary) | — | Conditional approval | | Early Feb 2026 | Protego | — | Conditional approval (second attempt; 2021 approval lapsed) | | Feb 23, 2026 | Crypto.com | — | Conditional approval | | Feb 18, 2026 | Morgan Stanley | — | Application filed | | Feb 24, 2026 | Payoneer | — | Application filed | | Mar 4-5, 2026 | Zerohash | — | Application filed | | Apr 2, 2026 | Coinbase (Coinbase National Trust Company) | De novo | Conditional approval | | Mar 25, 2026 | EDX Markets (EDX Trust, N.A.) | De novo | Application pending | | Jan 7, 2026 | World Liberty Financial (WLTC Holdings) | De novo | Application pending |

Prior to December 2025, only Anchorage Digital Bank had completed the full process from conditional approval to operational status, receiving its charter in January 2021.

What a National Trust Bank Charter Permits

National trust banks are a specific subset of national banks. They cannot accept consumer deposits or issue loans as primary activities. Their core function is holding, managing, and custodying assets. A single federal charter replaces the patchwork of state money transmitter licenses that crypto firms currently hold, allowing nationwide operations under one regulator.

As of September 30, 2025, OCC-supervised uninsured national trust banks reported $6.8 trillion in assets under administration, of which $1.6 trillion consisted of custody and safekeeping accounts.

The charter grants qualified custodian status under SEC regulations — a prerequisite for institutional clients such as pension funds, endowments, and registered investment advisors. It does not include FDIC insurance, deposit-taking authority, or lending powers.

The April 1 Rule Change

On February 27, 2026, the OCC filed an amendment to 12 CFR 5.20, published in the Federal Register on March 2, effective April 1. The change replaced the phrase "fiduciary activities" with "operations of a trust company and activities related thereto," aligning the regulatory text with statutory language in 12 U.S.C. 27(a).

The practical effect: the previous text created ambiguity about whether national trust banks could conduct non-fiduciary custody — specifically, holding digital assets without discretionary management authority. The OCC stated it had never restricted national trust banks to fiduciary services alone, and that the amendment merely codified existing interpretation. According to the OCC, "the regulatory text just caught up with the practice."

For crypto firms, non-fiduciary custody is the operational foundation. The amendment removed the last textual obstacle to digital asset custody as an explicit permissible activity.

Applicant Profiles and Charter Types

The applicants fall into three categories:

De novo applicants — building new federal entities from scratch:

  • Circle plans to operate First National Digital Currency Bank, likely custodying USDC reserves under direct federal oversight.
  • Ripple intends for Ripple National Trust Bank to custody RLUSD reserves and institutional digital assets under dual federal (OCC) and state (NYDFS) oversight.
  • Coinbase received conditional approval on April 2, 2026, for Coinbase National Trust Company, headquartered in New York. Coinbase currently serves as custodian for over 80% of the world's digital asset ETFs and manages approximately $245.7 billion in assets. Chief Legal Officer Paul Grewal confirmed Coinbase cannot operate under the charter until final approval is granted.
  • EDX Markets, backed by Citadel Securities, Charles Schwab, Virtu Financial, Paradigm, Sequoia Capital, and Hudson River Trading, filed on March 25 to charter EDX Trust, N.A. in Chicago for institutional digital asset custody and settlement. Order matching and trading would remain with its affiliate, EDX Markets LLC.

State trust company conversions — upgrading existing state charters:

  • BitGo, Fidelity Digital Assets, and Paxos all hold state trust company licenses and applied to convert them to national charters.

Stablecoin-focused applicants:

  • World Liberty Financial (linked to President Trump) filed January 7, 2026, specifically to issue and custody the USD1 stablecoin. Senator Elizabeth Warren requested the application be paused, citing concerns about a UAE entity's reported 49% stake in the company. Comptroller Gould stated the OCC would follow statutory time limits for review.

The Opposition: Banks, States, and Litigation Risk

The charter wave faces coordinated opposition from three directions.

Bank Policy Institute (BPI): The trade group — whose board includes CEOs of JPMorgan Chase, Goldman Sachs, and Citigroup — retained outside counsel by March 2026 to evaluate legal challenges to the OCC's chartering decisions. BPI's argument: crypto firms are receiving bank-like federal imprimatur without equivalent capital requirements, supervision intensity, or consumer protection obligations. As of March 10, no lawsuit had been filed; the association was still reviewing legal options.

Conference of State Banking Supervisors (CSBS): State regulators described the charter structure as a "Franken-charter," assembled from regulatory components not designed to work together. CSBS argues the OCC is stretching its authority under the National Bank Act by combining charter provisions to allow non-bank companies to operate nationwide. The Conference signaled potential legal challenge.

American Bankers Association (ABA): On March 5, 2026, the ABA rejected the White House compromise on federal stablecoin legislation, citing a Standard Chartered analysis projecting that yield provisions could redirect "$1 trillion in deposits away from traditional banks toward stablecoin products by 2028."

The legal vulnerability centers on whether the OCC exceeded its statutory authority. The 2021 precedent — when CSBS sued the OCC over its fintech charter proposal — was settled after the OCC withdrew the charter. The current trust bank charters stand on different legal footing, but the opposition's argument mirrors the earlier one: the OCC is creating a lighter regulatory pathway that undercuts the state-federal banking balance.

The Anchorage Precedent

Anchorage Digital Bank remains the only crypto firm to have completed the full journey from conditional approval to fully operational national trust bank status. It received its charter in January 2021, making it the first federally chartered cryptocurrency bank in the United States. In 2022, the OCC issued Anchorage a consent order related to anti-money-laundering deficiencies — a signal that the OCC does actively supervise these entities, but also that compliance failures are real.

Every current applicant must complete a pre-opening phase: initial board meeting, corporate bylaws, payment rail establishment, and a rigorous OCC examination. The gap between conditional approval and operational status took Anchorage several months and significant capital expenditure.

Federal Reserve Access: The Unresolved Question

The highest-stakes open question is whether these new national trust banks will receive access to Federal Reserve payment rails — specifically, master accounts at Federal Reserve Banks. Without a master account, a trust bank must clear transactions through correspondent banking relationships, adding cost and delay.

Federal Reserve Governor Chris Waller has publicly explored streamlined account structures for non-deposit-taking entities, but no formal rules or guidelines exist. The Federal Reserve has not established a framework for how it will handle master account applications from crypto-focused national trust banks. This gap is not academic: the ability to settle transactions directly through Fedwire, rather than through an intermediary, determines whether these charters create genuine competitive parity with traditional banks or remain structurally dependent on them.

Implications for Stablecoin Issuance

Several applicants — Circle, Ripple, and World Liberty Financial — explicitly intend to custody stablecoin reserves through their new charters. This creates a direct intersection with pending stablecoin legislation. The CLARITY Act, currently in Senate negotiations, would establish a federal framework for stablecoin issuance and regulation.

If both the trust bank charters and stablecoin legislation proceed, issuers could operate under dual federal authority: OCC supervision of the custodial entity and legislative requirements for the stablecoin itself. Coinbase's stablecoin-related revenue represented approximately 20% of its total revenue in Q3 2025, illustrating the economic significance of these operations.

The outcome could consolidate the largest stablecoin operations under federal supervision, reducing the patchwork of state money transmitter regimes that currently govern most stablecoin activity.

Key Takeaways

  • Twelve companies have received conditional OCC approval or filed national trust bank charter applications since December 12, 2025. Only Anchorage Digital Bank has previously completed the full process to operational status.
  • The April 1 rule change to 12 CFR 5.20 formally codified non-fiduciary custody as a permissible activity for national trust banks, removing the last textual ambiguity around digital asset custody.
  • The Bank Policy Institute, representing the largest U.S. banks, has retained outside counsel to evaluate legal challenges. The Conference of State Banking Supervisors labeled the charters "Franken-charters" and signaled potential litigation.
  • Federal Reserve master account access remains unresolved. Without it, new trust banks must rely on correspondent banking relationships, limiting operational independence.
  • Stablecoin issuers Circle, Ripple, and World Liberty Financial plan to custody reserves through these charters, creating a direct intersection with pending federal stablecoin legislation.
  • The sponsor bank model collapse in 2023-2024, when federal regulators scrutinized bank-fintech partnerships and several banks exited, created urgency for independent federal charters.

Conclusion

The OCC's trust bank charter wave represents the most significant structural shift in crypto-banking relations since Anchorage's 2021 approval. The pace — twelve applicants in under four months — reflects both the regulatory opening created by Comptroller Gould and the industry's desperation for a federal framework after the sponsor bank model collapsed.

Whether these charters survive legal challenge depends on two factors: the outcome of BPI's litigation review and the Federal Reserve's posture on payment rail access. A successful BPI lawsuit could freeze the chartering pipeline. Conversely, if the charters hold and the Federal Reserve extends master account access, the result would be a federally supervised crypto custody industry operating alongside traditional banks — exactly the "dynamic, competitive and diverse banking system" Comptroller Gould described.

The data is clear on the direction. The legal durability is not.

Sources & References

  1. Eleven Companies, Eighty-Three Days: The Race for a Federal Crypto Banking License — FinTech Weekly, comprehensive timeline of OCC charter applications
  2. OCC National Trust Bank Rule Takes Effect Today — FinTech Weekly, analysis of 12 CFR 5.20 amendment effective April 1, 2026
  3. OCC Announces Conditional Approvals for Five National Trust Bank Charter Applications — OCC official press release, December 12, 2025
  4. Coinbase Receives OCC Conditional Approval for National Trust Bank Charter — FinTech Weekly, April 2026
  5. Coinbase (COIN) Wins Initial OCC Nod for Trust Charter — CoinDesk, April 2, 2026
  6. Charles Schwab, Citadel-backed EDX Joins List of Crypto Firms Seeking National Trust Bank Charter — The Block, April 2026
  7. BPI Weighs Lawsuit Against OCC Over Licensing of Crypto and FinTech Firms — PYMNTS, March 2026
  8. US Banking Lobby Weighs Lawsuit Against OCC Over Crypto Trust Bank Charters — The Block, March 2026
  9. Coinbase Receives Conditional Approval for OCC Trust Charter — American Banker, April 2026
  10. World Liberty Financial Announces Application for National Trust Bank Charter — BusinessWire, January 7, 2026