Thirteen companies have filed for or received conditional national trust bank charters from the Office of the Comptroller of the Currency (OCC) since December 2025, ending a four-year freeze on federal crypto banking licenses that began under the Biden administration. The applicant pool spans cry...
"Today's conditional approval of Coinbase's trust charter application is a grave mistake that will only serve to put U.S. consumers at risk." — Rebeca Romero Rainey, President and CEO, Independent Community Bankers of America
Thirteen companies have filed for or received conditional national trust bank charters from the Office of the Comptroller of the Currency (OCC) since December 2025, ending a four-year freeze on federal crypto banking licenses that began under the Biden administration. The applicant pool spans crypto-native firms (Circle, Ripple, Coinbase), traditional Wall Street institutions (Morgan Stanley, Fidelity), fintech infrastructure providers (Zerohash, Bridge), and the Trump-linked World Liberty Financial.
An OCC rule amendment to 12 CFR 5.20, effective April 1, 2026, formally resolved a longstanding textual ambiguity in the chartering statute by replacing "fiduciary activities" with "operations of a trust company and activities related thereto." The change makes non-fiduciary digital asset custody an explicit function of national trust banks, removing the legal uncertainty that had discouraged applications for years.
The banking industry has responded with coordinated opposition. The Bank Policy Institute (BPI), representing Goldman Sachs, JPMorgan, and American Express, is weighing a lawsuit against the OCC, alleging that Interpretive Letter 1176 expanded charter eligibility without proper notice-and-comment rulemaking. The Independent Community Bankers of America (ICBA) called Coinbase's April 2 conditional approval "a grave mistake." The Conference of State Bank Supervisors labeled the charter structure a "Franken-charter."
Between December 12, 2025 and March 5, 2026 — a span of 83 days — eleven companies either received conditional OCC approvals or filed de novo charter applications. According to OCC records, the agency received fewer than four charter applications annually between 2011 and 2024. In 2025 alone, it received 14 de novo applications, nearly matching the prior four years combined.
December 12, 2025 — Five simultaneous conditional approvals:
This marked the first time the OCC granted multiple crypto-native firms conditional charters simultaneously. Circle and Ripple filed as de novo applicants, building new entities from scratch. BitGo, Fidelity Digital Assets, and Paxos converted from existing state trust companies.
February 2026 — Three more conditional approvals:
February–March 2026 — Three more applications filed:
April 2026 — Two more entrants:
Prior to this wave, only Anchorage Digital Bank held a fully operational OCC national trust bank charter for digital assets, having received its charter in January 2021 and remaining the sole such entity for over four years.
On February 27, 2026, the OCC filed an amendment to 12 CFR 5.20. Published in the Federal Register on March 2, the rule took effect April 1, 2026.
The amendment replaced the phrase "fiduciary activities" — which described the scope of national trust bank operations — with "operations of a trust company and activities related thereto." The OCC stated in its rulemaking that it had never interpreted the previous language to restrict national trust banks to fiduciary activities only. But the textual ambiguity existed, and the amendment eliminates it.
The revised language aligns with the statutory authority in 12 U.S.C. 27(a). The practical effect: national trust banks chartered by the OCC can now operate non-fiduciary custody accounts — including digital asset custody — under explicit regulatory authorization rather than interpretive guidance.
This distinction matters for institutional adoption. A bank operating under clear statutory language faces different litigation risk than one operating under an interpretive letter. For asset managers evaluating qualified custodians, the difference between "the OCC says it's allowed" and "the regulation explicitly says it's allowed" is material.
Coinbase received conditional approval on April 2, 2026 for Coinbase National Trust Company, a de novo non-insured national trust company headquartered in New York. The charter authorizes fiduciary custody, asset management, and related services under a single federal framework, replacing Coinbase's previous patchwork of state money transmitter licenses.
Coinbase Co-CEO Greg Tusar stated: "We will not be taking retail deposits. We will not be engaging in fractional reserve banking." The charter permits custody and market infrastructure services only.
EDX Markets, backed by Citadel Securities, Fidelity Digital Assets, Charles Schwab, Virtu Financial, Paradigm, Sequoia Capital, and Hudson River Trading, filed its application on March 25. If approved, EDX Trust would handle custody, asset management, and settlement for institutional clients. Order matching and trading would remain with its affiliate, EDX Markets LLC. The structural separation mirrors the exchange-clearinghouse model used in traditional equities markets.
Three distinct banking industry groups have raised formal objections.
The Bank Policy Institute (BPI), whose members include Goldman Sachs, JPMorgan, and American Express, is considering suing the OCC. According to reporting by The Block, BPI alleges that OCC Interpretive Letter 1176 expanded charter eligibility without formal notice-and-comment rulemaking — a potential violation of the Administrative Procedure Act. As of late April 2026, no lawsuit has been filed, but BPI's board has discussed the matter.
The Independent Community Bankers of America (ICBA) issued a statement opposing Coinbase's approval, calling it "a grave mistake." ICBA President Rebeca Romero Rainey cited "flawed risk and control functions, profitability challenges, and resolution risks." The ICBA has partnered with the Bank Policy Institute, National Community Reinvestment Coalition, and Fair Finance Watch to oppose similar applications.
The Conference of State Bank Supervisors (CSBS) characterized the charter structure as a "Franken-charter," questioning its long-term legal viability and raising concerns about federal preemption of state banking oversight.
The American Bankers Association separately estimated that yield-bearing stablecoins — a function some charter applicants intend to support — could trigger $1 trillion in deposit migration from traditional banks by 2028.
WLTC Holdings LLC, a subsidiary of Trump-linked World Liberty Financial (WLF), filed a de novo application in January 2026 to establish World Liberty Trust Company, National Association. The proposed entity would issue and custody the USD1 stablecoin and offer digital asset conversion services for institutional customers.
Senator Elizabeth Warren requested the OCC pause the application until President Trump divested his ownership interest. OCC Comptroller Jonathan Gould declined to halt the review but said he would consider sharing the unredacted application with the Senate Banking Committee.
Warren's inquiry focused on the disclosure of a $500 million stake in WLF acquired by a UAE-based entity shortly before the January 2025 inauguration. The question of whether this entity was disclosed as a principal shareholder in the charter application remains unresolved publicly.
A national trust bank charter from the OCC provides:
A national trust bank charter does not provide:
The gap between what the charter enables and what a full bank charter provides is the core tension. Charter holders gain the credibility and regulatory framework of federal banking without the capital requirements, stress testing, and resolution planning that apply to insured commercial banks. Critics argue this creates an asymmetric competitive advantage. Proponents argue the trust bank model has existed for decades without systemic incident.
The charter race restructures the custody value chain. Today, most crypto firms rely on a sponsor bank model — partnering with a chartered bank for custody and compliance. Under the new framework, firms can become their own custodians.
Zerohash exemplifies the infrastructure play. The company, which rejected a Mastercard acquisition offer of up to $2 billion in October 2025, raised $250 million at a $1.5 billion valuation in January 2026. Morgan Stanley invested in Zerohash's September 2025 Series D-2 round ($104 million) alongside Interactive Brokers. CEO Edward Woodford has described the company as "the Amazon Web Services of on-chain infrastructure." It serves over 5 million end users across 190 countries and counts Interactive Brokers, Stripe, BlackRock's BUIDL Fund, Franklin Templeton, DraftKings, and Kalshi among its clients.
The economic logic is clear: a federal charter reduces per-jurisdiction compliance costs, enables direct institutional relationships, and eliminates the margin extracted by sponsor banks. For firms with sufficient scale, the charter pays for itself through margin recapture. For smaller firms, the compliance burden of maintaining a national trust bank — estimated at $5-10 million annually in staffing and systems — may prove prohibitive.
The question of Federal Reserve payment rail access remains unresolved. Without Fedwire or FedACH access, charter holders must still route dollar settlements through correspondent banking relationships. This limits the cost savings and operational independence that the charter theoretically provides.
The OCC charter wave represents the most significant structural shift in U.S. crypto custody since Anchorage received the first federal charter in 2021. In fewer than five months, the pipeline went from one operational charter holder to 13+ applicants spanning crypto exchanges, Wall Street banks, fintech infrastructure firms, and politically connected entities.
The regulatory framework is clearer than it has ever been. The April 1 rule amendment removed the last significant textual ambiguity around trust bank custody authority. But the political and legal challenges are substantial: a potential BPI lawsuit, sustained ICBA opposition, unresolved Fed payment rail access, and the World Liberty Financial disclosure controversy.
The economic outcome depends on whether the charter delivers the cost savings and institutional credibility it promises — or whether the compliance burden and restricted functionality make it a regulatory trophy rather than a competitive advantage. The next twelve months, as conditional approvals convert (or fail to convert) to fully operational charters, will determine which it is.