Seventeen crypto and fintech firms have received conditional national trust bank charters from the U.S. Office of the Comptroller of the Currency since December 2025 — more than in the previous five years combined. Of those, three have cleared final approval: BitGo (January 2026), Circle (July 20...
"We are not becoming a commercial bank. We will not be taking retail deposits. We will not be engaging in fractional reserve banking." — Brian Armstrong, CEO, Coinbase
Seventeen crypto and fintech firms have received conditional national trust bank charters from the U.S. Office of the Comptroller of the Currency since December 2025 — more than in the previous five years combined. Of those, three have cleared final approval: BitGo (January 2026), Circle (July 2026), and Ripple (October 26, 2026). A fourth, Anchorage Digital, has held a federal charter since January 2021.
The pace has drawn a lawsuit. On October 2, the Independent Community Bankers of America filed suit against the OCC and Comptroller Jonathan Gould, alleging the agency exceeded its statutory authority. The case targets the March 2026 final rule underpinning the charter framework and seeks to block all future crypto trust bank approvals. Meanwhile, the GENIUS Act's January 2027 compliance deadline for stablecoin issuers is compressing the timeline, turning what might have been a multi-year rollout into a ten-month sprint.
This report compares the four firms that have obtained final federal charters, maps the 13 still in conditional status, and examines the legal and economic forces shaping who will — and who will not — make it through.
Before December 2025, exactly one crypto-native firm held a federal banking charter: Anchorage Digital Bank NA, chartered in January 2021. For nearly five years, Anchorage operated as the sole federally supervised crypto custodian, an anomaly in an industry that served hundreds of billions in assets through state-licensed entities.
That changed on December 12, 2025, when the OCC conditionally approved five applications in a single announcement: BitGo, Circle, Ripple, Fidelity Digital Assets, and Paxos. The approvals arrived under Comptroller Jonathan Gould, who had joined from Bitfury and signaled a posture favorable to digital-asset chartering.
The subsequent ten months produced 12 additional conditional approvals:
| Date | Firm | Type | |------|------|------| | Feb 2026 | Bridge (Stripe) | New charter | | Feb 2026 | Crypto.com | New charter | | Feb 2026 | Protego | Conversion from state trust | | Apr 2026 | Coinbase | New charter | | May 2026 | Laser Digital (Nomura) | New charter | | Aug 2026 | World Liberty Trust (Trump-affiliated) | New charter | | Sep 18, 2026 | Agora | New charter | | Sep 18, 2026 | Catena Labs | New charter | | Sep 18, 2026 | Bastion | New charter |
The total: 17 conditional approvals in 83 days of aggregate processing time, according to FinTech Weekly. Of those, four are conversions of existing state trust companies; 13 are new charters. Eight describe stablecoin issuance among their proposed activities.
National trust bank charters do not permit deposit-taking, lending, or FDIC insurance. They authorize fiduciary activities: custody, reserve management, settlement, and trust administration. Each of the four final-approval holders has carved a distinct position within those constraints.
BitGo cleared first, 48 days after receiving conditional approval. The firm's charter focuses on institutional digital-asset custody and settlement infrastructure. BitGo had operated as a state-regulated trust company and converted to a national trust bank. Its custody infrastructure underpins several third-party stablecoin programs, including — until August 2026 — World Liberty Financial's USD1 token.
Circle's charter entity, First National Digital Currency Bank NA (doing business as Circle National Trust), received final approval on July 10. The bank provides fiduciary digital-asset custody for Circle and its affiliates. Notably, management of the USDC reserve — Circle's $30 billion-plus stablecoin — was deferred to a future phase. At launch, the bank handles custody only; reserve management will require additional regulatory approval.
Ripple's RNTB received final approval ten months after conditional authorization. Its charter authorizes three specific functions: managing segregated reserves backing RLUSD (Ripple's stablecoin, with approximately $2.5 billion in circulation), acting as collateral trustee for those reserves on behalf of RLUSD holders, and providing fiduciary custody of digital assets. Unlike Circle's phased approach, Ripple's charter includes reserve management from day one.
Anchorage remains the longest-tenured federal crypto bank. In February 2026, Tether invested $100 million in Anchorage at a $4.2 billion valuation. Anchorage provides custody, staking, trading, and governance services to institutional clients. It operates under continuous OCC supervision, including Bank Secrecy Act and anti-money-laundering requirements, and holds qualified-custodian status under SEC rules.
| Metric | Anchorage | BitGo | Circle | Ripple | |--------|-----------|-------|--------|--------| | Charter date | Jan 2021 | Jan 2026 | Jul 2026 | Oct 2026 | | Primary function | Custody, trading, staking | Custody, settlement | Custody (reserve mgmt deferred) | Reserve mgmt, custody, trustee | | Stablecoin role | Custodian (third-party) | Custodian (third-party) | USDC issuer (reserve deferred) | RLUSD reserve manager | | Minimum capital | $10M+ | $10M+ | $10M+ | $10M+ | | FDIC insured | No | No | No | No |
The pattern is consistent: each charter holder occupies a different segment of the digital-asset value chain — trading infrastructure (Anchorage), settlement plumbing (BitGo), stablecoin issuance (Circle), and cross-border payments (Ripple).
Thirteen firms hold conditional approvals but have not yet cleared the OCC's final examination. The conditional-to-final gap has ranged from 48 days (BitGo) to over ten months (Ripple). Firms must hold a board meeting, adopt bylaws, establish payment rails, and pass a pre-opening examination.
Two firms in the original December 2025 batch — Paxos and Fidelity Digital Assets — still lack final approval after ten months. No public explanation has been given for the delay.
The conditional queue includes notable names across several categories:
Exchanges: Coinbase ($376 billion in institutional custody assets at time of application, per Forbes) and Crypto.com.
Payment infrastructure: Bridge, owned by Stripe, and Catena Labs.
Traditional finance: Laser Digital, the digital-asset arm of Nomura Holdings, representing the first major Japanese bank affiliate to seek a U.S. federal crypto charter.
Stablecoin issuers: Paxos (issuer of PYUSD for PayPal and BUSD historically), Agora, and Bastion.
Politically connected: World Liberty Trust Company, backed by the Trump family, received conditional approval August 14 with a $20 million minimum capital requirement. Its USD1 stablecoin has reached over $4 billion in circulation.
State conversions: Protego, which held a conditional charter from the OCC since 2021 and is converting to full national trust status.
The Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed into law in 2025, creates a compliance cliff. After January 2027, stablecoin issuers operating in the U.S. must hold either a national bank charter, operate as a federal branch, secure approval as a nonbank federal qualified payment stablecoin issuer, or clear the bar as a state-qualified issuer under frameworks meeting federal minimums.
The law mandates 1:1 reserve backing in specified assets, monthly attested reserve reports, and federal or state examination authority. For firms currently issuing stablecoins under state money-transmitter licenses — which describes most of the market — the January 2027 deadline requires a fundamental change in legal structure.
The OCC finalized its GENIUS Act implementation rule in September 2026, with an effective date of January 2027. Eight of the 17 charter applicants describe stablecoin issuance among their proposed activities. The regulatory deadline is likely accelerating applications and compressing the OCC's review timeline.
This explains the clustering: three approvals on a single day (September 18), followed by Ripple's final approval on October 26. The OCC appears to be processing at an unprecedented pace. Whether that pace survives judicial review is the open question.
On October 2, 2026, the Independent Community Bankers of America — representing over 5,000 U.S. community banks — filed suit against the OCC and Comptroller Gould in the U.S. District Court for the District of Columbia.
The lawsuit challenges the March 2026 final rule and Interpretive Letter No. 1176, which expanded the activities permissible for national trust banks to include crypto custody, trading, and stablecoin-related services. ICBA argues these activities are non-fiduciary in nature and therefore exceed the statutory authority granted to national trust banks under 12 U.S.C. §§ 27(a) and 92a.
The legal argument has academic support. A George Washington University Law School paper published in 2026 contends that the OCC violated four federal statutes by allowing national trust banks to engage in crypto-related non-fiduciary activities, including stablecoin issuance.
If the court grants ICBA's requested relief, the consequences would be significant: the ruling could void existing charters' authority to engage in non-fiduciary crypto activities and block future approvals under the contested framework. The case specifically targets the charter granted to Protego Holdings, but a broad ruling would affect all 17 conditional and final charter holders.
No preliminary injunction has been granted as of October 27. The case remains in early stages.
National trust banks operate under constraints that limit their revenue models compared to full-service banks. Without deposit-taking or lending authority, they cannot earn net interest income — the primary revenue source for traditional banks. Revenue derives instead from:
The OCC requires a minimum of $10 million in Tier 1 capital, with at least 50% or $5 million (whichever is greater) held in eligible liquid assets. World Liberty Trust received a higher threshold at $20 million.
The economic logic of seeking a federal charter, despite these constraints, rests on three factors: regulatory clarity that replaces a patchwork of 50 state licenses, qualified-custodian status that institutional clients increasingly require, and — for stablecoin issuers — GENIUS Act compliance.
The cost is non-trivial. Ongoing OCC supervision includes regular examinations, BSA/AML program requirements, cybersecurity standards, board governance obligations, and continuous reporting. For firms accustomed to lighter-touch state oversight, the operational burden represents a significant step change.
The OCC has issued more crypto-related trust bank charters in ten months than in the previous five years. The pace reflects both a permissive comptroller and a legislative deadline that leaves stablecoin issuers little choice but to apply. Three firms have crossed the finish line; 13 remain in queue; and a federal lawsuit threatens the legal foundation of the entire program.
The January 2027 GENIUS Act deadline will determine whether the remaining applicants accelerate through or face a compliance gap. The ICBA case, still in early stages, introduces a binary risk: if the court sides with community bankers, the OCC's authority to charter crypto trust banks for non-fiduciary activities could be curtailed, potentially stranding firms that built compliance programs around a framework that no longer holds.
For now, the four final-approval holders — Anchorage, BitGo, Circle, and Ripple — operate in a regulatory environment that is permissive but contested. Their charters are live. Whether they remain unchallenged depends on a federal judge in Washington.