Eleven companies filed for or received conditional national trust bank charters from the Office of the Comptroller of the Currency between December 12, 2025 and March 5, 2026 — an 83-day window that compressed years of regulatory inertia into weeks. The applicants span crypto-native custodians (B...
"The OCC seems to think that they can take bits and pieces of all these authorities and cobble them together in any number of 'Franken-charters' … but that is inconsistent with the history of the National Bank Act and the OCC's specific, limited chartering authority." — Brandon Milhorn, President and CEO, Conference of State Bank Supervisors
Eleven companies filed for or received conditional national trust bank charters from the Office of the Comptroller of the Currency between December 12, 2025 and March 5, 2026 — an 83-day window that compressed years of regulatory inertia into weeks. The applicants span crypto-native custodians (BitGo, Paxos, Circle), traditional financial institutions (Morgan Stanley, Fidelity), stablecoin infrastructure firms (Bridge, Zerohash), and exchange operators (Coinbase, Crypto.com). Two additional applications — Coinbase and World Liberty Financial — remain pending.
The charter wave was enabled by an OCC rule amendment, effective April 1, 2026, that replaced "fiduciary activities" in 12 CFR 5.20 with "operations of a trust company and activities related thereto." The change resolved a textual ambiguity that had limited national trust banks to fiduciary work, opening the door for non-fiduciary custody — the core business model for digital asset custodians. The result: a parallel federal banking infrastructure for crypto assets, operating alongside the traditional banking system but subject to different capital, deposit insurance, and Fed access rules.
The move has triggered opposition from three banking trade groups — the Bank Policy Institute (BPI), the American Bankers Association (ABA), and the Conference of State Bank Supervisors (CSBS) — with BPI actively weighing litigation as of March 2026. Standard Chartered analysts estimated that stablecoin-related provisions alone could redirect $1 trillion from traditional bank deposits by 2028.
The OCC issued conditional approvals to its first five crypto-focused applicants on December 12, 2025: Circle (filed as First National Digital Currency Bank), Ripple (Ripple National Trust Bank), BitGo, Fidelity Digital Assets, and Paxos. Three were conversions from existing state trust company charters; two were de novo applications.
A second wave followed in February 2026. Bridge, the stablecoin infrastructure subsidiary acquired by Stripe in 2024, received conditional approval around February 12. Protego, which had attempted and failed to secure a charter in 2021, was approved in early February. Crypto.com received its conditional approval on February 23.
Three more applications arrived before March 5: Morgan Stanley filed for a subsidiary called Morgan Stanley Digital Trust, National Association on February 18. Payoneer followed on February 24. Zerohash, which provides the crypto infrastructure underlying Morgan Stanley's ETRADE platform, filed on March 5.
Coinbase received its conditional approval on April 2, 2026, bringing the total to twelve conditional approvals and one pending application (World Liberty Financial).
A national trust bank charter authorizes the holder to hold, manage, and custody assets for clients across all 50 states under a single federal regulator — the OCC. This replaces the patchwork of state money transmitter licenses that most crypto firms currently maintain.
Permitted activities include: custody of digital assets, fiat currency, and other assets; custodial staking and validation; transfer agent services; trade execution; stablecoin management; and settlement, clearing, and escrow services.
The charter does not permit: accepting retail deposits, lending against deposits, or offering FDIC insurance on customer accounts. These entities are not banks in the traditional deposit-taking sense. They cannot access the Federal Reserve's payment infrastructure or discount window without separate authorization — authorization that does not yet exist in any formal framework.
As Comptroller Jonathan V. Gould stated upon approving the first five charters: "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."
On February 27, 2026, the OCC filed an amendment to 12 CFR 5.20, published in the Federal Register on March 2. The amendment replaced "fiduciary activities" with "operations of a trust company and activities related thereto," aligning regulatory text with the statutory language in 12 U.S.C. 27(a). The rule took effect April 1, 2026.
The OCC stated it had never interpreted "fiduciary activities" to limit national trust banks to fiduciary work exclusively. The change eliminated textual ambiguity rather than expanding authority, according to the agency. Critics disagree with that characterization.
The practical effect: national trust banks can now explicitly operate non-fiduciary custody accounts — the primary service model for institutional digital asset custody. Prior to the amendment, the legal basis for this activity under a national trust charter was subject to conflicting interpretations.
| Company | Filing Date | Status | Charter Type | Notable Detail | |---------|------------|--------|-------------|----------------| | Circle | Dec 12, 2025 | Conditional | De novo | Filed as First National Digital Currency Bank | | Ripple | Dec 12, 2025 | Conditional | De novo | Ripple National Trust Bank | | BitGo | Dec 12, 2025 | Final (Jan 2026) | Conversion | First to reach final approval; IPO at $2.08B valuation | | Fidelity Digital Assets | Dec 12, 2025 | Conditional | Conversion | Extends existing $4.7T AUM custodial infrastructure | | Paxos | Dec 12, 2025 | Conditional | Conversion | State trust company conversion | | Bridge (Stripe) | ~Feb 12, 2026 | Conditional | — | Stablecoin infrastructure acquired by Stripe in 2024 | | Protego | Early Feb 2026 | Conditional | — | Second attempt; failed in 2021 | | Crypto.com | Feb 23, 2026 | Conditional | — | Exchange operator expanding to custody | | Morgan Stanley | Feb 18, 2026 | Pending | De novo | Morgan Stanley Digital Trust, N.A. | | Payoneer | Feb 24, 2026 | Pending | — | Payments infrastructure firm | | Zerohash | Mar 5, 2026 | Pending | — | Powers Morgan Stanley, BlackRock, Franklin Templeton | | Coinbase | Apr 2, 2026 | Conditional | — | Replaces patchwork of state MTL licenses | | World Liberty Financial | — | Pending | — | Application pending |
BitGo stands out as the first to reach final OCC approval, which it received following its January 22, 2026 NYSE listing. The IPO priced at $18 per share, raising $212.8 million at a $2.08 billion valuation. Shares opened 24.6% higher, pushing the market cap to $2.59 billion on day one. Goldman Sachs and Citigroup led the offering. BitGo also holds MiCA-compliant custody and trading licenses from BaFin in Germany and VASP and broker-dealer approvals from VARA in Dubai, giving it arguably the most geographically diverse regulatory portfolio among pure-play custodians.
Zerohash warrants particular attention. The Chicago-based firm provides the crypto infrastructure underlying Morgan Stanley's ETRADE platform, BlackRock, Franklin Templeton, Stripe, and Interactive Brokers. A federal charter would give Zerohash a single regulatory framework to custody assets for these clients' wealth management operations, operate as stablecoin infrastructure under the GENIUS Act framework, and scale institutional relationships without maintaining separate state licenses.
Three major banking trade groups have issued formal objections:
Bank Policy Institute (BPI): The trade group, whose members include Goldman Sachs, JPMorgan, and American Express, was actively weighing litigation as of March 2026, according to reporting by The Block. BPI has argued that charter recipients should face the same capital and compliance standards as full-service banks.
Conference of State Bank Supervisors (CSBS): President Brandon Milhorn, speaking at the Carolina Bank Directors Forum in Charlotte on March 3, 2026, warned that the OCC is "cobbling together" authorities into what he termed "Franken-charters." Milhorn stated: "Litigation is certainly a possibility … to ensure that the OCC does not overstep its authority." CSBS also argued the OCC "appears to reserve to itself unfettered discretion to allow trust banks that are also payment stablecoin issuers to engage in activities beyond those specifically delineated in the GENIUS Act."
American Bankers Association (ABA): The ABA rejected White House stablecoin compromise provisions that would allow yield on stablecoin tokens. Standard Chartered analysts estimated such provisions could redirect $1 trillion from traditional bank deposits to stablecoin products by 2028.
No lawsuit had been filed as of April 17, 2026.
The crypto custody provider market grew from $3.28 billion in 2025 to an estimated $3.69 billion in 2026, according to 360iResearch, with a projected CAGR of 13.05% to $7.74 billion by 2032. Assets under professional crypto custody now exceed $200 billion.
For the charter applicants, the economic logic is straightforward. Custody generates recurring, fee-based revenue that is structurally different from trading commissions. A federal charter consolidates regulatory overhead (replacing dozens of state licenses with one federal regulator), enables cross-state institutional client onboarding, and positions the holder as a qualified custodian — a prerequisite for managing assets on behalf of registered investment advisers under SEC Rule 206(4)-2.
The value chain extends beyond asset safekeeping. Custody clients generate adjacent revenue through staking services, settlement and clearing, stablecoin management, and trade execution. Zerohash's application, for instance, listed six distinct service categories beyond basic custody.
For traditional banks, the threat is not custody fees per se but the deposit base. If stablecoin issuers operating under trust charters can offer yield-bearing instruments, the flow of deposits from traditional banks to stablecoin products becomes a structural risk — the $1 trillion figure cited by Standard Chartered analysts.
Federal Reserve access: None of the newly chartered entities have been granted access to the Federal Reserve's payment infrastructure, the discount window, or Fed master accounts. Fed Governor Chris Waller has explored a "streamlined account structure" but no formal framework exists. Without Fed access, these entities depend on correspondent banking relationships for fiat settlement — a dependency that limits operational independence.
GENIUS Act interaction: The pending GENIUS Act stablecoin legislation would establish a federal framework for stablecoin issuance. Several charter applicants (Circle, Paxos, Bridge) are stablecoin issuers or infrastructure providers. CSBS has warned that the OCC may be preemptively expanding trust bank permissions beyond what the GENIUS Act envisions, creating regulatory overlap.
CLARITY Act status: The broader crypto market structure legislation remains stalled. Without it, the trust charter provides custody and stablecoin permissions but leaves token classification, exchange regulation, and DeFi protocol oversight in regulatory limbo.
Litigation timeline: BPI's decision on whether to sue the OCC could reshape the charter landscape. A successful legal challenge could force conditional approvals to be rescinded or narrowed.
The OCC's 83-day charter sprint has created a new category of federal financial institution — one that sits between traditional banks and state-licensed money transmitters. The 13 entities now holding or seeking these charters include crypto-native custodians, Wall Street incumbents, payment processors, and stablecoin infrastructure firms. They share a common bet: that institutional digital asset custody requires federal-level regulatory standing.
Whether this structure survives depends on three unresolved variables: the outcome of potential BPI litigation, the passage and final form of the GENIUS Act, and the Federal Reserve's eventual decision on payment system access for trust-chartered entities. The banking lobby's opposition is not symbolic — the deposit base implications of yield-bearing stablecoins issued by federally chartered entities represent a measurable threat to traditional banking's core funding model.
The charter wave is, at its core, an infrastructure play. Custody, staking, settlement, and stablecoin management are the plumbing of institutional crypto adoption. The OCC has decided this plumbing belongs in the federal system. The courts, Congress, and the Fed will determine whether that decision holds.