Thirteen companies have filed for or received conditional OCC national trust bank charters since December 12, 2025 — the fastest regulatory land grab in U.S. crypto history. On April 2, Coinbase became the latest conditional approval, joining Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets,...
"We will not be taking retail deposits. We will not be engaging in fractional reserve banking. This charter is about bringing federal regulatory uniformity to the custody and market infrastructure business." — Greg Tusar, Head of Institutional Finance, Coinbase
Thirteen companies have filed for or received conditional OCC national trust bank charters since December 12, 2025 — the fastest regulatory land grab in U.S. crypto history. On April 2, Coinbase became the latest conditional approval, joining Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Bridge, Crypto.com, and Protego. Morgan Stanley, Payoneer, Zerohash, and EDX Markets have pending applications. World Liberty Financial, the Trump-family-linked stablecoin venture, filed separately in January.
The OCC's amended chartering rule, effective April 1, 2026, formally codified what these charters permit: non-fiduciary custody alongside traditional trust operations. The Bank Policy Institute is preparing a legal challenge. The ICBA has called the approvals "a grave mistake." Traditional banks see a threat; crypto firms see a passport. The outcome will determine whether digital asset custody becomes a federally regulated utility or remains trapped in a patchwork of 50 state licensing regimes.
Between December 12, 2025, and March 5, 2026, eleven entities filed for or received conditional OCC national trust bank charters — more than the OCC had processed for crypto-adjacent firms in the prior four years combined. The OCC received 14 de novo charter applications in 2025 alone, nearly matching the total from the previous four years.
Batch 1 — December 12, 2025 (5 conditional approvals):
Batch 2 — February 2026 (3 conditional approvals):
Pending applications filed February–April 2026:
The pace reflects a policy shift under Comptroller Jonathan Gould, who has stated his intention to "level the playing field" and promote "diversity" in U.S. financial services. The OCC currently supervises approximately 60 national trust banks holding nearly $2 trillion in custody accounts. The crypto entrants are adding to, not replacing, this infrastructure.
A national trust bank charter under the National Bank Act is a special-purpose charter. It does not permit deposit-taking, lending, or FDIC insurance. It authorizes the holder to:
The charter does not convert a crypto firm into a bank in any conventional sense. There is no access to the Federal Reserve discount window or to Fed payment rails — a point of active contention. The entity is not an FDIC-insured depository institution.
Conditional approval is not operational approval. Each applicant must satisfy pre-opening requirements: compliance systems, AML/BSA frameworks, risk management infrastructure, staffing benchmarks, and a pre-opening OCC examination. According to standard OCC procedure, this process takes months.
On April 1, 2026, the OCC's amended chartering rule (12 CFR 5.20) took effect. The revision replaced the phrase "fiduciary activities" — when used to describe permissible national trust bank operations — with "the operations of a trust company and activities related thereto."
The practical effect: the regulation now explicitly accommodates non-fiduciary custody accounts, the core service model for digital asset custodians. The OCC stated it had never interpreted the prior language as prohibiting non-fiduciary custody, but the amendment removes a potential legal foothold for future challenges.
The rule was published in the Federal Register on March 2, 2026. The Conference of State Banking Supervisors raised concerns about the legal structure during the comment period. The amendment passed without modification.
Coinbase filed its application on October 3, 2025, and received conditional approval on April 2, 2026. The entity — Coinbase National Trust Company — will be headquartered in New York and operate as a de novo non-insured national trust company.
Coinbase is the largest digital asset custodian globally by assets. According to company disclosures and industry reports:
The charter consolidates Coinbase's custody operations under a single federal regulator, replacing dozens of state licenses. Chief Legal Officer Paul Grewal stated: "Consistent rules and regulatory trust are what allow us to innovate with confidence."
The conditional approval requires Coinbase to build out compliance systems, hire additional staff, pass regulatory reviews, and demonstrate risk management and AML controls before receiving final authorization. No timeline for final approval has been disclosed.
The charter wave has triggered coordinated opposition from the traditional banking sector. Three organizations have taken public positions against the OCC's approach:
Independent Community Bankers of America (ICBA): ICBA President Rebeca Romero Rainey called the Coinbase approval "a grave mistake that will only serve to put U.S. consumers at risk." The ICBA alleges that Coinbase's application contains inadequate risk controls, unclear profitability prospects, and unresolved resolution risks. The ICBA joined the Bank Policy Institute (BPI), National Community Reinvestment Coalition (NCRC), and Fair Finance Watch (FFW) in opposing Bridge's charter application earlier in the cycle.
Bank Policy Institute (BPI): According to reporting by The Block, BPI is preparing a lawsuit against the OCC. The legal team is reportedly in active preparation, though no filing has been made as of early April. The legal core of the dispute centers on OCC Interpretive Letter 1176 (2021), which expanded the scope of permissible activities for trust banks.
American Bankers Association (ABA): The ABA requested the OCC suspend the approval process entirely. The trade group has pressed regulators to prevent non-deposit-taking entities from using the word "bank" in their names, arguing it misleads consumers into assuming FDIC insurance coverage.
The banking lobby's substantive argument: national trust bank charters allow crypto firms to access benefits of bank regulatory status — federal preemption, single-regulator efficiency, qualified custodian designation — without bearing the costs of FDIC insurance, Community Reinvestment Act obligations, or Bank Holding Company Act oversight.
Anchorage Digital Bank remains the only crypto firm to have moved from OCC conditional approval to fully operational national trust bank status. Its trajectory is instructive.
Anchorage received its charter in January 2021 — the first federally chartered crypto bank. In 2022, the OCC issued a consent order citing Bank Secrecy Act/AML compliance failures. That order was terminated in August 2025 after Anchorage demonstrated remediation. The OCC stated that "the safety and soundness of the Bank and its compliance with laws and regulations does not require the continued existence of the Order."
The lesson for the 13 current applicants: conditional approval is the starting line, not the finish. Anchorage's three-year compliance journey — including a public enforcement action — illustrates the operational burden of maintaining a federal charter. Paxos and Protego both saw prior conditional approvals expire after failing to meet the 18-month operational window required by OCC rules.
The digital asset custody market is valued at approximately $3.3–$3.7 billion in annual service revenue (2026 estimates vary by research firm). Assets under professional custody exceed $200 billion across institutional providers. Grand View Research projects the broader digital asset custody market reaching $4.4 trillion in assets by 2033, at a compound annual growth rate of 23.6%.
Custody revenue is structurally different from exchange trading revenue. It generates recurring, fee-based income tied to assets held, not trading volume. For Coinbase, this distinction is material: Q4 2025 institutional transaction revenue was $61 million versus $650 million consumer. But custody fees provide margin stability that trading cannot.
The federal charter addresses a specific economic bottleneck. Without qualified custodian status under SEC rules, digital asset custodians cannot serve registered investment advisers managing client assets. A September 2025 SEC no-action letter clarified that state-chartered trust companies can qualify, but a national charter provides cleaner legal footing and eliminates state-by-state variability.
The charter wave acquired a political dimension in January 2026 when WLTC Holdings LLC — a subsidiary of World Liberty Financial, co-founded by Eric Trump, Donald Trump Jr., and Barron Trump — filed a de novo application to establish World Liberty Trust Company, National Association. The entity would issue and custody USD1, a dollar-pegged stablecoin that has reached over $3.3 billion in circulation.
Senator Elizabeth Warren requested the OCC pause the review, citing presidential conflicts of interest. Comptroller Gould responded that the application would follow the standard review process. The application remains pending.
The World Liberty filing introduces a complication for the broader charter cohort: any political controversy surrounding one application risks tainting the regulatory framework used by all applicants. Banking lobby groups have referenced the World Liberty application in their broader critiques of the OCC's chartering approach.
The OCC's national trust bank charter has become the de facto federal licensing pathway for digital asset custody in the United States. Thirteen applications in under four months represent a structural shift, not a trend. The entry of Morgan Stanley alongside crypto-native firms signals that the charter's utility extends beyond the crypto industry into traditional finance.
The unresolved questions are legal, not operational. If the BPI lawsuit materializes, it could challenge the OCC's interpretive authority under the National Bank Act and potentially freeze the pipeline. If it does not, the custody market will consolidate rapidly around a small number of federally chartered entities — a development consistent with the economic logic of infrastructure standardization, but one that raises concentration risk questions the existing reports on this site have documented across other blockchain verticals.
The data is clear on one point: the era of state-by-state licensing for institutional crypto custody is ending. What replaces it — a functioning federal framework or a legal stalemate — depends on outcomes still in motion.