The Office of the Comptroller of the Currency has approved or conditionally approved national trust bank charters for at least 13 crypto firms under the current administration, according to an October 2026 court filing by the Independent Community Bankers of America. Two have crossed the finish l...
"For years, we've said crypto and banks work better together. Final approval for Ripple National Trust Bank is what that looks like in practice." — Brad Garlinghouse, CEO, Ripple
The Office of the Comptroller of the Currency has approved or conditionally approved national trust bank charters for at least 13 crypto firms under the current administration, according to an October 2026 court filing by the Independent Community Bankers of America. Two have crossed the finish line with final, unconditional approvals: Circle on July 10, 2026, and Ripple on October 30, 2026. At least four more — BitGo, Fidelity Digital Assets, Paxos, and Crypto.com — hold conditional approvals and are working through pre-opening requirements.
The charter wave coincides with the OCC's October 21 finalization of a 721-page GENIUS Act rule that, beginning January 18, 2027, will require any entity issuing a payment stablecoin in the United States to be an approved "permitted payment stablecoin issuer" or face criminal penalties. The convergence of charter approvals and the GENIUS Act framework is remaking the boundary between crypto firms and the federally regulated banking system — and drawing a lawsuit from community banks that argue the OCC has exceeded its statutory authority.
This report tracks the charter pipeline, examines the regulatory architecture being assembled around stablecoin issuance, and assesses the legal and structural risks ahead.
The OCC's national trust bank charter has become the preferred federal entry point for crypto firms seeking regulatory credibility without applying for a full commercial banking license. The current pipeline, based on public filings and press releases:
| Firm | Entity Name | Status | Date | Primary Use Case | |------|-------------|--------|------|-----------------| | Circle | First National Digital Currency Bank, N.A. (dba Circle National Trust) | Final approval | Jul 10, 2026 | USDC custody, reserve mgmt | | Ripple | Ripple National Trust Bank | Final approval | Oct 30, 2026 | RLUSD reserves, institutional custody | | BitGo | BitGo B&T (conversion) | Conditional | Dec 2025 | Digital asset custody | | Fidelity Digital Assets | (conversion from state charter) | Conditional | Dec 2025 | Institutional custody | | Paxos | (conversion from state charter) | Conditional | Dec 2025 | Stablecoin issuance, custody | | Crypto.com | Foris Dax National Trust Bank (dba Crypto.com National Trust Bank) | Conditional | Feb 2026 | Asset custody, trade settlement |
According to the ICBA's October 2 filing, the OCC has approved or conditionally approved 21 national trust banks under the current administration, at least 13 of which are crypto companies.
A national trust bank charter is a limited banking license. It confers federal preemption of state law — meaning the charter holder operates under one federal regulator rather than a patchwork of state requirements. It permits fiduciary activities: managing assets held in trust on behalf of clients.
What it does not permit: accepting deposits, issuing loans, or obtaining FDIC insurance. Trust banks are not deposit-taking institutions. They are not covered by the Community Reinvestment Act. Their customers' assets are not protected by federal deposit insurance.
This distinction is central to the legal dispute now unfolding. The ICBA argues that the OCC has effectively created a "fourth category" of national bank — entities that neither accept deposits nor exercise traditional fiduciary powers, but instead conduct crypto-native activities (custody, reserve management, trade settlement) under the trust bank label. The OCC maintains these activities fall within the scope of fiduciary powers authorized by the National Bank Act.
Capital requirements vary by institution. The OCC's GENIUS Act final rule sets a floor of $5 million for newly approved payment stablecoin issuers, but in practice, minimum tier 1 capital has ranged from $15 million to $60 million based on individual charter approvals reviewed by the OCC.
Circle became the first major stablecoin issuer to obtain an unconditional OCC charter when it received final approval on July 10, 2026. The entity — First National Digital Currency Bank, N.A., doing business as Circle National Trust — will provide fiduciary digital asset custody for Circle and its affiliates.
USDC, Circle's dollar-pegged stablecoin, holds approximately $78 billion in market capitalization as of late October 2026, representing roughly 23% of the total $297 billion stablecoin market. Circle applied for the charter in June 2025, received conditional approval in December 2025, and cleared final review in seven months.
At present, Circle National Trust offers custody services internally. The company has indicated it may extend institutional custody to banks and regulated financial institutions, subject to additional OCC approval. Reserve management for USDC is described as a "future capability" — the trust bank does not yet directly manage USDC's reserve portfolio.
Circle's stock surpassed Coinbase in market capitalization during 2026, reflecting investor confidence in its regulated-infrastructure strategy. The company is also subject to European Banking Authority supervision under MiCA beginning November 12, 2026, after USDC was classified as the EU's first "significant" e-money token.
Ripple received unconditional OCC approval on October 30, 2026 — the effective charter date, though the public announcement came on October 26. Ripple National Trust Bank will manage segregated reserves backing RLUSD and serve as collateral trustee for RLUSD holders.
RLUSD has grown 88% year-to-date, reaching approximately $2.5 billion in market capitalization as of late October 2026, according to DefiLlama data. Supply is split between Ethereum ($1.71 billion) and the XRP Ledger ($710 million). The stablecoin was the third-fastest-growing by market cap in 2026, adding over $1 billion this year alone.
RLUSD will continue to be issued by Standard Custody & Trust Company, Ripple's New York Department of Financial Services-regulated entity. The new national trust bank adds a second regulatory layer: RLUSD now operates under both state (NYDFS) and federal (OCC) oversight.
Reserves, according to Ripple, are held in cash and short-dated U.S. Treasuries with daily attestations. The OCC charter brings those reserves under federal prudential standards, including capital requirements, anti-money-laundering controls, and regular OCC examinations.
Ripple first applied in July 2025, received conditional approval in December 2025, and waited ten months for final sign-off — three months longer than Circle's timeline.
Four firms hold conditional OCC approvals but have not yet received final charters. Each must satisfy pre-opening requirements covering capital adequacy, governance structures, risk management frameworks, and internal compliance policies before the OCC signs off.
BitGo received conditional approval in December 2025 to convert its existing state trust charter (BitGo Trust Company, Inc.) to a national trust bank. SEC filings from early 2026 reference the conversion to BitGo B&T. The company completed its IPO in January 2026. Its primary use case is institutional digital asset custody.
Fidelity Digital Assets — the crypto custody arm of Fidelity Investments, which manages over $5 trillion in assets — received conditional approval to convert from its state charter in December 2025. Final approval timing has not been publicly disclosed.
Paxos Trust Company holds a conditional approval for conversion. Paxos operates the PYUSD stablecoin for PayPal and its own Paxos Dollar (USDP). A federal charter would give Paxos a single federal regulator for its stablecoin and custody operations.
Crypto.com received conditional approval in February 2026. The entity — Foris Dax National Trust Bank, doing business as Crypto.com National Trust Bank — applied in October 2025. The charter would allow the Singapore-headquartered exchange to custody client assets and handle trade settlement under federal supervision, but not to take deposits or issue loans.
None of the four have disclosed expected dates for final approval.
On October 21, 2026, the OCC published a 721-page final rule implementing the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act. The rule takes effect January 18, 2027. After that date, any entity issuing a "payment stablecoin" in the United States must be an approved "permitted payment stablecoin issuer" (PPSI). Noncompliance carries criminal penalties.
Key provisions of the final rule:
The rule received 328 public comments during the notice-and-comment period. The OCC has not yet begun accepting PPSI applications, pending approval of associated information-collection forms by the Office of Management and Budget.
The January deadline creates urgency across the stablecoin industry. Firms that have not secured a charter or equivalent regulatory status by that date risk being unable to legally issue stablecoins in the United States.
The regulatory expansion has drawn opposition from the community banking sector. On October 2, 2026, the Independent Community Bankers of America filed suit against the OCC in U.S. District Court for the District of Columbia, challenging the legal basis for crypto trust charters.
The complaint targets two OCC actions: the March 2, 2026, final rule and Interpretive Letter No. 1176. The ICBA alleges both exceed the OCC's authority under the National Bank Act.
ICBA CEO Rebeca Romero Rainey stated: "Congress did not create the national trust charter as a side door into the banking system for crypto firms seeking the credibility of a federal bank charter."
The core argument: the National Bank Act authorizes three types of national banks — traditional depository banks, bankers' banks, and national trust banks that exercise fiduciary powers. The ICBA contends the OCC has effectively created a fourth category for entities that neither accept deposits nor perform traditional fiduciary functions, granting them federal preemption of state law without requiring FDIC insurance, Community Reinvestment Act compliance, or equivalent capital standards.
The complaint states that two ICBA member banks, each with under $2.5 billion in assets, have already lost business to crypto firms holding conditional trust charters. The ICBA asks the court to vacate the March 2026 rule, vacate Interpretive Letter 1176, and void the conditional charter of Protego, which the suit names specifically.
The outcome of the case could determine whether the remaining conditional approvals — including those held by BitGo, Fidelity, Paxos, and Crypto.com — survive legal scrutiny.
The OCC's national trust charter has become the federal gateway for crypto firms to enter the regulated banking system. In under 12 months, two of the five originally approved applicants — Circle and Ripple — have cleared final review. Four more hold conditional approvals with no disclosed timeline for completion.
The GENIUS Act final rule, effective January 2027, raises the stakes. Any firm issuing a dollar-denominated payment stablecoin without an approved charter or equivalent status will be subject to criminal penalties. This creates a regulatory moat around incumbent issuers with active or pending OCC relationships and a deadline pressure for everyone else.
The ICBA lawsuit introduces legal risk that applies to the entire charter pipeline. If the court rules that the OCC exceeded its authority under the National Bank Act, some or all of these charters could be vacated. The case, filed in the D.C. district court, is in early stages, and no ruling is expected before mid-2027.
For the stablecoin market — now approaching $300 billion — the question is whether the charter-plus-GENIUS framework will entrench existing issuers or open the system to new entrants. The January 2027 deadline suggests the former: firms with active OCC relationships hold a structural advantage. Those without face a narrowing window and rising compliance costs.