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WEBTHREEPEDIA RESEARCH

[COMPARATIVE ANALYSIS] Crypto's Great Bank Charter Land Grab

Zephyra|March 3, 2026|BPF
EXECUTIVE SUMMARY

A quiet regulatory revolution is underway at the Office of the Comptroller of the Currency. Since December 2025, seven crypto-native firms have received conditional approval for national trust bank charters — and at least a dozen more applications are pending. Circle, Ripple, Paxos, BitGo, Fideli...

"Coinbase has never had a year without being subject to an enforcement action." — Independent Community Bankers of America (ICBA), letter to the OCC opposing Coinbase's national trust bank charter application

Executive Summary

A quiet regulatory revolution is underway at the Office of the Comptroller of the Currency. Since December 2025, seven crypto-native firms have received conditional approval for national trust bank charters — and at least a dozen more applications are pending. Circle, Ripple, Paxos, BitGo, Fidelity Digital Assets, Stripe's Bridge, and Crypto.com now hold federally supervised banking structures. Morgan Stanley filed its application on February 18, 2026. Nomura's Laser Digital filed in January. World Liberty Financial, the Trump family-linked crypto venture, is pushing through over Senate opposition.

This is not incremental change. It is a structural transformation of who gets to operate as a bank in America. A single OCC rule change — replacing "fiduciary activities" with "operations of a trust company and activities related thereto," effective April 1, 2026 — has opened the door for crypto custody to become a primary banking function, not a side activity. The result is a land grab for federal banking legitimacy that is drawing both crypto insurgents and Wall Street incumbents into a collision course, while the traditional banking lobby fights to slow it down.

The digital asset custody market is projected to reach $1.05 trillion in assets under custody in 2026, growing at a 23.6% compound annual rate. The firms securing charters today are positioning to capture the infrastructure layer of this market under the imprimatur of the U.S. federal banking system.

Table of Contents

  1. The OCC's Open Door
  2. Seven Approvals and Counting
  3. The April 1 Rule Change
  4. The Applicant Pipeline
  5. Wall Street Joins the Queue
  6. The Banking Lobby Pushback
  7. The Political Dimension
  8. Economic Value Analysis
  9. Key Takeaways
  10. Conclusion

The OCC's Open Door

The Office of the Comptroller of the Currency has processed more crypto-related charter applications in the last 90 days than in its entire prior history. Eighteen firms applied for OCC charters in 2025 alone, with 14 de novo applications filed across 2025 and early 2026. The OCC's dedicated Digital Assets Licensing Applications page — a resource that did not exist 18 months ago — now tracks a rolling pipeline of filings, comment periods, and conditional approvals.

The charter structure being pursued is the national trust bank — a specific category that allows firms to offer custody, safekeeping, staking, and settlement services under federal supervision, but explicitly prohibits accepting deposits or issuing loans. This is a critical distinction: these are not full-service banks. They are federally regulated custodians operating under the trust company framework.

This matters for economic value distribution because the trust bank model captures a specific, high-margin slice of the financial stack — custody fees, settlement revenue, and staking commissions — without bearing the capital-intensive obligations of deposit-taking institutions.

Seven Approvals and Counting

As of March 2026, seven firms hold conditional OCC approvals for national trust bank charters:

| Firm | Proposed Entity | Approval Date | Primary Focus | |------|----------------|---------------|---------------| | Circle | First National Digital Currency Bank | Dec 2025 | Stablecoin issuance, reserves | | Ripple | Ripple National Trust Bank | Dec 2025 | XRP Ledger integration, custody | | BitGo | BitGo Bank & Trust, NA | Dec 2025 | Institutional custody, stablecoin | | Fidelity | Fidelity Digital Assets, NA | Dec 2025 | Wealth management custody | | Paxos | Paxos Trust Company, NA | Dec 2025 | Custody, tokenization | | Bridge (Stripe) | Bridge National Trust Bank | Feb 2026 | Stablecoin infrastructure | | Crypto.com | Foris Dax National Trust Bank | Feb 2026 | Custody, staking, settlement |

Each must still satisfy OCC conditions — capital adequacy, governance structures, risk management frameworks, and AML/BSA compliance — before receiving final authorization. The process typically takes 6 to 12 months after conditional approval.

The December 2025 approvals were notable for including both de novo charters (Circle, Ripple) and state-to-federal conversions (BitGo, Fidelity Digital Assets, Paxos), signaling the OCC's willingness to accommodate multiple organizational structures.

The April 1 Rule Change

On February 27, 2026, the OCC finalized a rule change that quietly reshapes the legal foundation for these charters. The updated regulation replaces the phrase "fiduciary activities" with "operations of a trust company and activities related thereto" in the regulatory language governing national trust banks.

The practical effect: national trust banks can now treat custody and safekeeping as core business activities, not ancillary functions tied to a fiduciary mandate. For crypto firms, this removes a longstanding legal ambiguity about whether holding digital assets constitutes a trust function under federal banking law.

The rule takes effect April 1, 2026. It applies retroactively to all conditionally approved charters and will govern all pending applications.

The Bank Policy Institute and Conference of State Banking Supervisors have formally objected, arguing that many applicants are not running genuine trust companies and should face the same capital and compliance standards as full-service banks. Their concern is not abstract: if custody is reclassified as a core trust activity, the capital requirements for crypto custodians could remain significantly lower than those for deposit-taking institutions handling comparable asset volumes.

The Applicant Pipeline

Beyond the seven approved firms, the OCC pipeline includes several high-profile applicants:

Coinbase — Filed for a national trust bank charter but faces organized opposition. The ICBA has called on the OCC to deny the application, citing Coinbase's history of enforcement actions across multiple jurisdictions, including a 2023 NYDFS consent order for AML failures and a 2025 Connecticut order for unlicensed money transmission. The ICBA's formal position: Coinbase's "demonstrably flawed risk and control functions" disqualify it from operating under a national banking framework.

World Liberty Financial — The Trump family-linked firm applied in January 2026 through subsidiary WLTC Holdings LLC, seeking a charter to issue and custody USD1 stablecoins. Senator Elizabeth Warren has urged OCC Comptroller Jonathan Gould to reject the application, warning he could become "an accomplice" to corruption. Gould, a Trump appointee, has indicated he will follow statutory timelines. The comment period for this application has drawn intense scrutiny from both parties.

Nomura's Laser Digital — The digital assets arm of Japanese banking giant Nomura filed in January 2026, seeking to offer custody, spot trading, and staking services under federal supervision. If approved, it would become the first foreign bank subsidiary to hold a crypto-focused national trust charter.

Revolut, PayPal, and Erebor Bank are also reported to have applications in progress, though details remain limited.

Wall Street Joins the Queue

The most significant development may not be the crypto-native applications but the entry of traditional Wall Street institutions. On February 18, 2026, Morgan Stanley filed with the OCC to establish Morgan Stanley Digital Trust National Association, a wholly owned subsidiary headquartered in Purchase, New York.

Morgan Stanley's application explicitly covers custody, safekeeping, and staking services for its wealth management clients. The strategic intent, as reported by PYMNTS, is less about launching a crypto exchange and more about owning "the custody, settlement, and fiduciary plumbing layer of blockchain finance under U.S. bank supervision." The filing supports Morgan Stanley's parallel initiative to partner with Zerohash to enable crypto trading through E-Trade.

This represents a convergence: crypto-native firms are pursuing federal banking charters to gain legitimacy, while traditional banks are pursuing the same charters to capture crypto revenue without ceding the custody layer to newcomers. The OCC comment period for Morgan Stanley's application closes March 20, 2026.

The Banking Lobby Pushback

The American Bankers Association — the largest banking lobby in the United States — has formally called on the OCC to pause all crypto-related charter approvals until the GENIUS Act, the federal stablecoin law passed in 2025, is fully implemented.

The ABA's objections center on three arguments:

  1. Regulatory gaps. Approving trust bank charters before Congress defines stablecoin reserve requirements, receivership protocols, and securities-banking boundary lines risks creating entities that fall between regulatory frameworks.

  2. Precedent risk. The ABA warns that premature approvals could "repeat the failures of FTX and Celsius" by granting banking legitimacy to firms whose risk controls remain untested under federal banking standards.

  3. Naming conventions. The ABA demands stricter rules preventing limited-purpose crypto trust entities from using the word "bank" in their official names, arguing that consumers may confuse trust banks with FDIC-insured deposit institutions.

The ICBA has taken an even harder line, filing formal opposition to Coinbase's application and calling for enhanced capital requirements across all crypto trust applicants.

Comptroller Gould has shown no indication of slowing the process. The OCC continues to process applications within standard statutory timelines.

The Political Dimension

The charter wave cannot be separated from the political environment. Comptroller Gould is a Trump appointee who has consistently signaled a pro-innovation posture toward digital assets. The World Liberty Financial application, backed by the sitting president's family, has intensified questions about conflicts of interest.

Senator Warren's opposition represents the Democratic position that crypto banking charters require stronger consumer protections. Senator Scott, the Republican Banking Committee chairman, has been more receptive to charter expansion. OCC Comptroller Gould told the Senate Banking Committee on February 26 that he would consider sharing unredacted charter application materials with both the chairman and ranking member.

The political overlay creates an unusual dynamic: the same regulatory body is simultaneously processing applications from a presidential family venture, crypto exchanges with enforcement histories, traditional Wall Street banks, and foreign financial institutions. The OCC has never managed a charter pipeline this politically charged.

Economic Value Analysis

The economic value distribution of national trust bank charters tilts heavily toward custody and settlement infrastructure providers — the firms securing charters today.

Revenue model: National trust banks generate revenue through custody fees (typically 5-50 basis points annually on assets under custody), settlement and clearing fees, and staking commissions (where the bank takes a percentage of validator rewards). Unlike deposit-taking banks, they do not earn net interest margin from lending.

Market sizing: The global digital asset custody market is projected to reach $1.05 trillion in assets under custody in 2026, growing at a 23.6% CAGR. At a blended custody fee of 15 basis points, this represents approximately $1.6 billion in annual custody revenue — before settlement, staking, and ancillary service fees.

Competitive moat: A federal charter creates a structural advantage in three ways. First, it eliminates the need for state-by-state licensing, reducing compliance overhead. Second, it enables access to the Federal Reserve's payment systems. Third, it provides institutional clients with the fiduciary protections and regulatory certainty they require to allocate. For institutional allocators bound by fiduciary duty, a federally chartered custodian is not a preference — it is a requirement.

The firms that secure final charters will effectively control the tollbooths between institutional capital and on-chain assets.

Key Takeaways

  • Seven crypto firms now hold conditional OCC trust bank charters, with at least six more applications pending, including Morgan Stanley and the Trump-linked World Liberty Financial.
  • The April 1, 2026 OCC rule change redefines custody as a core trust bank activity, removing a key legal barrier for crypto custodians operating under federal supervision.
  • The ABA has formally called for a pause on all crypto charter approvals until the GENIUS Act is fully implemented, citing systemic risk and regulatory gap concerns.
  • Morgan Stanley's February 2026 filing signals that traditional Wall Street institutions are now competing directly with crypto-native firms for the same federal charter structures.
  • The digital asset custody market is projected at $1.05 trillion in assets under custody in 2026, making the charter race a fight over the infrastructure layer of institutional crypto adoption.
  • Political risk is elevated. The World Liberty Financial application and the OCC's pro-innovation posture under Comptroller Gould have made charter policy a partisan issue.

Conclusion

The crypto bank charter wave of 2025-2026 represents one of the most consequential structural shifts in U.S. financial regulation in decades. It is not a deregulatory free-for-all — the OCC's conditional approval process imposes genuine capital, governance, and compliance requirements. But it is a deliberate expansion of who gets to operate under the federal banking umbrella.

The winners will not necessarily be the largest firms or the most politically connected. They will be the firms that can satisfy the OCC's operational requirements fastest while building the custody and settlement infrastructure that institutional capital demands. The losers will be firms that assumed state-level money transmitter licenses and third-party custody arrangements were sufficient for institutional-grade operations.

For the broader Web3 ecosystem, the implications are profound. Federally chartered crypto custodians will become the gravitational center for institutional capital flows into digital assets. Protocol teams, DeFi platforms, and token issuers that cannot integrate with these regulated rails risk being cut off from the largest pools of capital in the world.

The land grab is underway. The April 1 rule change will accelerate it. The question is no longer whether crypto firms will become banks — it is which ones will survive the process.

Sources & References

  1. OCC Announces Conditional Approvals for Five National Trust Bank Charter Applications — Official OCC announcement of December 2025 approvals for Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos
  2. Crypto.com Receives Conditional Approval from OCC for National Trust Bank Charter — Crypto.com official announcement, February 23, 2026
  3. Morgan Stanley Applies for Bank Charter to Custody Crypto Assets — Bloomberg, February 27, 2026
  4. OCC Rule Effective April 1, 2026 Lets Crypto Trust Banks Treat Custody as Core — Coverage of OCC final rule on trust bank activity definitions
  5. National Bank Chartering: Final Rule — Official OCC bulletin on the rule change
  6. ICBA Urges OCC to Deny Coinbase's Application for a National Trust Bank Charter — ICBA formal opposition letter
  7. ABA Calls on OCC To Slow Crypto Bank Charter Approvals — Banking Exchange coverage of ABA position
  8. Trump-linked World Liberty Financial applies for federal bank charter — CoinDesk, January 7, 2026
  9. Nomura's Laser Digital applies to open U.S. national trust bank for crypto custody — CoinDesk, January 28, 2026
  10. Stripe's stablecoin firm Bridge wins initial approval to form national bank trust charter — CoinDesk, February 17, 2026
  11. Warren grills Gould over World Liberty charter application — Banking Dive, February 26, 2026
  12. Morgan Stanley's OCC Application Is Wall Street Colonizing Crypto — PYMNTS analysis
  13. Digital Asset Custody Market Size — Business Research Insights market projections
  14. OCC Digital Assets Licensing Applications — Official OCC application tracker