Thirteen crypto and financial-technology firms have filed for or received Office of the Comptroller of the Currency national trust bank charters since December 2025. Block's September 8, 2026, application for Builders Bank & Trust, N.A. — which would collapse 50-plus state money transmitter licen...
"Building on Block's experience in the digital asset space, our history with Square Financial Services and the deep banking expertise of the team we've assembled, we believe Builders Bank is well positioned to support Block's broader vision of economic empowerment." — Lee Woolley, Block's Digital Asset Strategy Lead and proposed CEO of Builders Bank & Trust, N.A.
Thirteen crypto and financial-technology firms have filed for or received Office of the Comptroller of the Currency national trust bank charters since December 2025. Block's September 8, 2026, application for Builders Bank & Trust, N.A. — which would collapse 50-plus state money transmitter licenses into a single federal custody vehicle — is the latest entry in a charter wave that has no precedent in U.S. banking history. In 83 days between December 2025 and early March 2026 alone, eleven companies submitted applications.
The applicants span the full width of digital-asset finance: crypto-native exchanges (Coinbase, Kraken parent Payward), stablecoin issuers (Circle, Paxos), payments infrastructure (Ripple, Bridge/Stripe, Zerohash), custody specialists (BitGo, Fidelity Digital Assets), a consumer fintech (Block), and one bulge-bracket investment bank (Morgan Stanley). Circle's First National Digital Currency Bank received final OCC approval on July 10, 2026, becoming the first crypto-native firm to complete the process since Anchorage Digital Bank in January 2021.
This report maps the charter pipeline by applicant type, regulatory status, proposed services, and strategic rationale. It examines the economic incentives driving the migration from state-by-state licensing to federal supervision — and the organized opposition from the traditional banking lobby that may yet slow it.
Prior to the GENIUS Act's passage, 60 national trust banks operated in the United States. Since December 2025, nearly 30 de novo applications have been filed with the OCC through early 2026, according to the agency's own count. The crypto-adjacent cohort accounts for 13 of those, moving through the pipeline at various stages:
| Applicant | Entity Name | Type | Status (Sept. 2026) | |---|---|---|---| | Circle | First National Digital Currency Bank, N.A. | De novo | Final approval (July 10, 2026) | | BitGo | BitGo Bank & Trust, N.A. | Conversion (SD) | Final approval (2026) | | Ripple | Ripple National Trust Bank, N.A. | De novo | Conditional (Dec. 2025) | | Fidelity Digital Assets | Fidelity Digital Assets, N.A. | Conversion (state) | Conditional (Dec. 2025) | | Paxos | Paxos Trust Company, N.A. | Conversion (state) | Conditional (Dec. 2025) | | Bridge (Stripe) | — | — | Conditional (Feb. 2026) | | Protego | — | — | Conditional (Feb. 2026) | | Crypto.com | — | — | Conditional (Feb. 2026) | | Morgan Stanley | Morgan Stanley Digital Trust, N.A. | De novo | Conditional (2026) | | Coinbase | Coinbase National Trust Company | De novo | Conditional (April 2026) | | Zerohash | — | — | Application filed (March 2026) | | Payward (Kraken) | Payward National Trust Company | De novo | Application filed (May 2026) | | Block | Builders Bank & Trust, N.A. | De novo | Application filed (Sept. 8, 2026) |
Two entities — Circle and BitGo — have received final approval and are operationally live. BitGo holds the distinction of being the first publicly traded, federally chartered digital-asset infrastructure company following its January 2026 NYSE listing.
A national trust bank charter issued by the OCC authorizes:
It does not authorize deposit-taking or commercial lending. These are uninsured entities; customer holdings do not carry FDIC insurance. The distinction matters: trust banks operate under a lighter capital and supervisory framework than full-service national banks, a point the banking lobby has seized upon.
An April 1, 2026, OCC rule amendment to 12 CFR 5.20 removed a textual ambiguity around non-fiduciary activities, confirming that non-fiduciary custody accounts — the product most crypto firms intend to offer — were authorized from inception.
The economic case for a federal charter is straightforward: regulatory consolidation. A firm operating nationwide under state-level money transmitter licenses must obtain and maintain separate authorizations in each jurisdiction — typically 48 to 52 licenses. The cost structure includes:
Block's filing makes the economics explicit. The company has operated bitcoin services for roughly eight years across more than 50 state money transmitter and virtual currency licenses, processing approximately $10.7 billion in Bitcoin volume in 2025. A single federal charter collapses those 50-plus licenses into one supervisor, one examination cycle, and one compliance framework.
Coinbase's filing disclosed $376 billion in crypto assets under custody at year-end 2025, representing approximately 13% of total crypto market capitalization. For custodians of that scale, the operational overhead of multi-state licensing is material.
Federal preemption is the key legal mechanism. According to Norton Rose Fulbright, state laws requiring a national bank to hold a state money transmitter license as a condition of engaging in charter-authorized business are preempted by federal law. A national trust charter thus provides not just regulatory simplification but nationwide operating authority by operation of law.
The GENIUS Act, signed into law in early 2026, fundamentally altered the regulatory calculus. The act established a federal framework for "permitted payment stablecoin issuers" (PPSIs) and created explicit pathways for OCC-licensed entities to issue stablecoins.
Key provisions relevant to trust charter applicants:
The act's penalty structure created urgency. Firms that lack a qualifying license or charter by July 2028 face compounding daily fines. For stablecoin issuers and custodians alike, the OCC national trust charter became the clearest path to federal compliance.
Circle — First National Digital Currency Bank, N.A. Filed June 30, 2025. Conditional approval December 2025. Final approval July 10, 2026 — the first crypto-native firm to complete the full process since Anchorage. Initial services: fiduciary digital-asset custody for Circle affiliates, with planned expansion to institutional clients and future reserve management capability for USDC.
BitGo — BitGo Bank & Trust, N.A. Converted from South Dakota state trust company. Final OCC approval in 2026. Became the first publicly traded, federally chartered digital-asset infrastructure firm after its January 2026 NYSE IPO. Authorized for custody, safekeeping, and nationwide digital asset services. Plans to issue a stablecoin.
Coinbase — Coinbase National Trust Company Conditional approval April 2, 2026. Brings federal uniformity to a custody business that previously operated solely under New York DFS oversight. The company reported $376 billion in assets on platform at year-end 2025. Not a commercial bank; no retail deposits or fractional reserve banking.
Morgan Stanley — Morgan Stanley Digital Trust, N.A. Filed February 18, 2026. The sole bulge-bracket entrant. Proposed activities: custody, purchase/sale/swap/transfer of digital assets, and fiduciary staking. Conditional approval received in 2026. Brings $9.2 trillion in client assets — the largest balance sheet attached to any applicant by orders of magnitude.
Block — Builders Bank & Trust, N.A. Filed September 8, 2026 — the most recent application. Uninsured national trust bank for bitcoin and stablecoin custody. Would consolidate 50-plus state licenses into a single federal vehicle. Proposed CEO: Lee Woolley, Block's Digital Asset Strategy Lead. Block processed $10.7 billion in Bitcoin volume through Cash App in 2025 and holds 8,780 BTC ($533.4 million) on its corporate balance sheet as of June 2026.
Payward (Kraken) — Payward National Trust Company Filed May 8, 2026. Would add a federally regulated trust company to Kraken's existing Wyoming special purpose depository institution (SPDI) chartered in 2020 and Fed master account. Focus: fiduciary custody and qualified-custodian designation for institutional allocators.
Fidelity Digital Assets — Fidelity Digital Assets, N.A. Conditional approval December 2025. Planned services include custodial accounts, trade execution, IRA services, settlement-as-a-service, collateral agency, stablecoin issuance, and staking. Final approval pending as of August 2026.
The Bank Policy Institute (BPI), representing 40 major U.S. banks including JPMorgan Chase, Goldman Sachs, and Citigroup, has mounted organized opposition. BPI's stated objections center on regulatory asymmetry: crypto firms would offer bank-like services under a lighter supervisory framework than full-service national banks, which must maintain FDIC insurance, higher capital ratios, and submit to more frequent examination.
The Independent Community Bankers of America (ICBA) filed similar objections, specifically against Payward's application. The National Community Reinvestment Coalition (NCRC) opposed Kraken's application on community reinvestment grounds.
BPI has retained outside counsel and actively considered litigation against the OCC. As of late July 2026, no suit had been filed. The organization urged the OCC to reject applications from crypto firms and raised concerns that conditional approvals left unanswered questions about whether requirements were tailored to actual activities and risks.
Bloomberg Law reported that traditional banks have "slammed" the OCC's approval process. The banking industry's core argument: national trust charters are being stretched beyond their historical purpose to accommodate a new class of financial institution that competes with banks without bearing equivalent regulatory costs.
The OCC national trust bank charter has become the preferred regulatory vehicle for crypto-native firms, stablecoin issuers, and — now — at least one Wall Street bank to gain federal operating authority for digital-asset custody and related services. The 13-applicant pipeline represents more than $400 billion in combined assets under custody or on platform, with Morgan Stanley's $9.2 trillion client base adding a structural order of magnitude.
The economic logic is clear: a single federal supervisor replaces a patchwork of 50-plus state licenses, with federal preemption eliminating jurisdictional fragmentation. The GENIUS Act's compliance deadlines and penalty structure converted what was an option into an urgency.
Whether the banking lobby's opposition translates into litigation or legislative constraint remains the principal risk. If BPI files suit against the OCC, the charter pipeline could slow materially. For now, the OCC continues to process applications, and the migration from state to federal licensing proceeds at pace.
The value proposition maps to a familiar pattern in financial infrastructure: firms are spending upfront regulatory capital to secure long-term operational efficiency. The trust charter wave is not about innovation — it is about plumbing. The question is not whether crypto custody moves to the federal banking perimeter, but how many firms the perimeter can absorb before the rules of entry change.