Eleven companies filed for or received conditional approval for OCC national trust bank charters between December 12, 2025, and March 5, 2026 — an 83-day window that represents the most concentrated burst of federal banking charter activity in the agency's modern history. During all of 2025, the ...
"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." — Jonathan Gould, Comptroller of the Currency, OCC
Eleven companies filed for or received conditional approval for OCC national trust bank charters between December 12, 2025, and March 5, 2026 — an 83-day window that represents the most concentrated burst of federal banking charter activity in the agency's modern history. During all of 2025, the OCC received 14 de novo charter applications, a number nearly equaling the total received in the previous four years combined. Barely 2.5 months into 2026, the agency has already approved four new applications and received more than seven.
The applicants include Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Stripe's Bridge, Crypto.com, Protego, Morgan Stanley, Payoneer, and Zerohash. Additional applications from Coinbase, Trump-linked World Liberty Financial, and Sony's Connectia Trust subsidiary remain pending. The OCC's final rule, effective April 1, 2026, explicitly clarifies that national trust banks can conduct non-fiduciary activities including crypto custody — a regulatory change that underwrites the entire wave.
The charter race is not occurring in a vacuum. It is timed to the GENIUS Act's July 18, 2026, deadline, by which federal regulators must finalize implementation rules for stablecoin issuance. These charters are on-ramps to stablecoin issuance under federal oversight. The Bank Policy Institute, the Independent Community Bankers of America, and the Conference of State Bank Supervisors have all objected, with the BPI openly considering litigation. The outcome will define whether crypto firms operate under lighter regulatory frameworks than traditional banks or face equivalent prudential requirements.
The OCC's December 12, 2025, announcement conditionally approved five applicants in a single batch:
| Company | Charter Type | Status | |---------|-------------|--------| | Circle (First National Digital Currency Bank) | De novo | Conditionally approved (Dec 2025) | | Ripple National Trust Bank | De novo | Conditionally approved (Dec 2025) | | BitGo Bank & Trust | State-to-national conversion | Conditionally approved (Dec 2025) | | Fidelity Digital Assets | State-to-national conversion | Conditionally approved (Dec 2025) | | Paxos Trust Co. | State-to-national conversion | Conditionally approved (Dec 2025) | | Bridge National Trust Bank (Stripe) | De novo | Conditionally approved (early 2026) | | Crypto.com (Foris DAX National Trust Bank) | De novo | Conditionally approved (Feb 2026) | | Protego (National Digital Trust Co.) | De novo | Conditionally approved (early 2026) | | Morgan Stanley | De novo subsidiary | Filed Feb 18, 2026 | | Payoneer | De novo | Filed Feb 24, 2026 | | Zerohash | De novo | Filed Mar 4, 2026 |
Morgan Stanley's application is structured to support its partnership with Zerohash, announced in September 2025, to enable crypto trading through its E*TRADE platform in the first half of 2026. Zerohash already powers infrastructure for Morgan Stanley, BlackRock, Franklin Templeton, Stripe, and Interactive Brokers, according to FinTech Weekly.
Additional pending applications include Coinbase National Trust Company and Sony's Connectia Trust, NA, a subsidiary seeking to issue dollar-pegged stablecoins and offer non-fiduciary digital asset custody.
National trust bank charters are narrower than full-service bank charters. They do not permit deposit-taking, checking or savings accounts, or access to FDIC insurance. These are not banks in the traditional consumer sense.
What they do permit, per the OCC's framework:
The critical distinction: these entities operate under federal banking supervision without the capital requirements, Community Reinvestment Act obligations, or Bank Holding Company Act restrictions that apply to FDIC-insured institutions. This is the core of the opposition from traditional banking lobbies.
On March 2, 2026, the OCC finalized amendments to its chartering regulation. Effective April 1, 2026, the rule replaces the phrase "fiduciary activities" — when describing the scope of national trust bank operations — with "the operations of a trust company and activities related thereto."
The change is technical but consequential. The prior language created ambiguity about whether national trust banks could engage in non-fiduciary custody — specifically, holding digital assets without managing them under a fiduciary duty. The amended language removes that ambiguity.
According to analysis by Stinson LLP, the Final Rule "makes the authorization unambiguous and resistant to a future challenge based on regulatory text alone." For crypto applicants, this means custody can be treated as a core business activity rather than an ancillary one.
The Guiding and Establishing National Innovation for U.S. Stablecoins Act, signed by President Trump in July 2025, requires payment stablecoins to be backed 1:1 by high-quality reserves — primarily U.S. dollars, Treasury bills, or cash equivalents. It bans issuer-paid yield on stablecoins.
The law sets a hard deadline: federal banking regulators must finalize implementation rules by July 18, 2026, exactly one year after enactment. The GENIUS Act takes effect on the earlier of 120 days after final rules are issued, or January 18, 2027.
Both the OCC and FDIC are tracking toward this deadline. The FDIC approved a proposed rule on December 16, 2025, allowing FDIC-supervised banks to issue payment stablecoins through subsidiaries. The OCC followed with its own notice of proposed rulemaking on February 25, 2026, per the Federal Register.
The charter race is therefore a positioning exercise. Companies securing conditional approvals now will be first in line to issue federally supervised stablecoins once implementation rules take effect. Those without charters face a longer regulatory path.
Running parallel to the GENIUS Act is the CLARITY Act, the market structure bill currently stalled in the Senate. The central dispute: whether stablecoin issuers can offer yield on dollar-denominated tokens.
On March 5, 2026, the American Bankers Association formally rejected a White House-brokered compromise. The rejected proposal would have permitted yield in limited peer-to-peer payment contexts while prohibiting it on idle balances. The ABA argued the provision would allow crypto firms to offer deposit-like products without deposit-like regulation.
Standard Chartered analysts estimated that a yield provision, if enacted, could redirect up to $500 billion in deposits from traditional banks toward stablecoin products by 2028.
On March 20, 2026, Senators Thom Tillis (R-NC) and Angela Alsobrooks (D-MD) confirmed a revised agreement: passive yield earned for holding a dollar-pegged token is banned; activity-based rewards tied to payments, transfers, or platform usage remain permitted, according to CoinDesk and Disruption Banking. This compromise, if codified, preserves the ABA's core demand while giving crypto firms limited room.
CSBS Chair Brandon Milhorn publicly described the OCC's approach as creating a "Frankenstein charter" — repurposing a narrow charter originally intended for trust activities into a broad-purpose digital asset vehicle. "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,'" Milhorn stated, according to Banking Dive. "That is inconsistent with the history of the National Bank Act and the OCC's specific, limited chartering authority."
CSBS retains the option to pursue litigation, which would represent the most significant legal confrontation in U.S. banking regulation since CSBS sued the OCC in 2020 over its fintech charter program.
BPI, whose members include Goldman Sachs, American Express, and JPMorgan, is openly considering suing the OCC, according to Invezz. BPI argues that national trust bank charters allow firms to offer bank-like services under a lighter regulatory framework, and that the "national trust bank" label could confuse consumers into believing these entities carry FDIC insurance.
ICBA has filed opposition letters against individual charter applications from Coinbase, Ripple, Circle, and Sony's Connectia Trust. ICBA's position is that the OCC should impose a moratorium on pending and new charter applications until it issues a final rule that "fully aligns with statutory intent and incorporates public comments."
World Liberty Financial, the crypto firm in which President Trump holds financial interests, filed for a national trust charter in January 2026. The proposed entity — World Liberty Trust Company — would directly issue the USD1 stablecoin.
Senator Elizabeth Warren requested the OCC delay its review until the President divests. Comptroller Gould declined, stating: "The only political pressure I have felt from any part of the United States government, senator, is from you." The application remains pending.
Disclosures indicate the United Arab Emirates acquired a 49% stake in World Liberty Financial shortly before Trump's inauguration. OCC regulations require charter applicants to disclose all shareholders with at least a 10% direct or indirect stake. The intersection of presidential financial interests and federal banking charter approval is without modern precedent.
The charter race underscores a fundamental economic question: where does the value in stablecoin infrastructure actually accrue?
Under the current architecture, stablecoin issuers earn yield on reserves — primarily from U.S. Treasuries — while token holders receive zero. Circle reported $1.7 billion in reserve income in 2024. Tether reported $6.3 billion in net profit for the same year. The GENIUS Act's yield ban preserves this dynamic at the federal level: issuers capture the spread, users get utility.
The national trust bank charter amplifies this structure. Charter holders avoid the capital requirements and compliance costs that traditional banks bear, while accessing federal legitimacy and supervision. The cost of maintaining a national trust bank is materially lower than maintaining a full-service national bank. The revenue — from custody fees, settlement fees, and reserve yield — flows to charter holders with fewer regulatory frictions.
For traditional banks, the threat is less about deposits (the yield ban protects that flank) and more about settlement infrastructure. If stablecoin-native firms build the custody and settlement rails under federal charters, they become the infrastructure layer for tokenized finance. The $500 billion deposit redirection estimate from Standard Chartered may be the visible concern, but the deeper risk is disintermediation from the plumbing itself.
The 83-day charter sprint is not a crypto sideshow. It is a structural repositioning of the U.S. financial system's settlement layer. The applicants include the largest stablecoin issuers (Circle, Paxos), the largest cross-border payment networks (Ripple, Payoneer), a top-three U.S. bank (Morgan Stanley), and infrastructure providers embedded in Wall Street's digital asset plumbing (Zerohash, BitGo).
The opposition from BPI, ICBA, and CSBS is substantive, not ceremonial. The central question — whether crypto firms can operate under lighter prudential standards than traditional banks while accessing federal legitimacy — remains unresolved. The April 1 rule change and the July 18 GENIUS Act deadline will force resolution in the coming months.
The outcome determines whether stablecoin infrastructure in the United States is built inside the banking system, alongside it, or in regulatory arbitrage against it. The 11 charter applications in 83 days suggest the market has already placed its bet. The regulators, the courts, and Congress will determine whether that bet pays off.