The Office of the Comptroller of the Currency has received 40 de novo bank charter applications in 18 months, the largest wave of new bank formation since the 2008 financial crisis. At least 13 of those applications involve digital asset firms seeking national trust bank charters — a category tha...
"We don't have a zero risk tolerance anymore. The statute talks about a reasonable chance of success. That's how we evaluate applications." — Jonathan V. Gould, Comptroller of the Currency, OCC
The Office of the Comptroller of the Currency has received 40 de novo bank charter applications in 18 months, the largest wave of new bank formation since the 2008 financial crisis. At least 13 of those applications involve digital asset firms seeking national trust bank charters — a category that barely existed two years ago. The result is a structural rewiring of how crypto firms access the U.S. financial system: not through partnership with existing banks, but by becoming banks themselves.
The numbers tell the story. Between December 2025 and August 2026, the OCC conditionally approved national trust bank charters for Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos, Bridge (Stripe), Crypto.com, Protego, Coinbase, Laser Digital (Nomura), and World Liberty Financial. Morgan Stanley, Payoneer, and Zerohash have pending applications. One applicant — Wise — was denied on AML grounds. Circle completed the full journey to final approval on July 10, 2026, joining Anchorage Digital as the only crypto-native firms operating as federally chartered banks. The Bank Policy Institute, representing JPMorgan, Goldman Sachs, and Citigroup, has retained counsel to potentially challenge the OCC's approach in court.
This is no longer a regulatory experiment. It is the formation of a parallel banking infrastructure built on digital asset rails.
Two regulatory changes created the conditions for this wave.
First, on December 12, 2025, the OCC simultaneously conditionally approved five national trust bank charter applications — Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos. This was the first time a federal banking regulator granted such charters to crypto firms in a single batch. It signaled intent.
Second, an OCC amendment to 12 CFR 5.20 took effect April 1, 2026. The rule replaced the phrase "fiduciary activities" with "operations of a trust company and activities related thereto." The change eliminated ambiguity about whether national trust banks could hold assets in non-fiduciary custody accounts — the core function crypto custodians need. The amendment was published in the Federal Register on March 2, 2026, giving applicants a clear legal foundation.
Comptroller Gould framed the shift bluntly: "America and the OCC are once again open for business." He added that "de novo chartering is a sign of a healthy banking system" and characterized the previous era's low application rates as "a disgrace."
The OCC reported deciding many complete applications within 120 days.
The following table summarizes the status of known digital asset national trust bank charter applicants as of August 24, 2026:
| Company | Filing Type | Conditional Approval | Final Approval | Status | |---------|-----------|---------------------|----------------|--------| | Circle (First National Digital Currency Bank) | De novo | Dec 2025 | Jul 10, 2026 | Operational | | Ripple National Trust Bank | De novo | Dec 2025 | Pending | Pre-opening | | BitGo Bank & Trust, N.A. | State-to-federal conversion | Dec 2025 | Pending | Pre-opening | | Fidelity Digital Assets, N.A. | State-to-federal conversion | Dec 2025 | Pending | Pre-opening | | Paxos Trust Company, N.A. | State-to-federal conversion | Dec 2025 | Pending | Pre-opening | | Bridge National Trust Bank (Stripe) | — | Feb 2026 | Pending | Pre-opening | | Protego | — | Feb 2026 (re-approval) | Pending | Pre-opening | | Crypto.com | — | Feb 23, 2026 | Pending | Pre-opening | | Morgan Stanley Digital Trust N.A. | — | Filed Feb 18, 2026 | — | Application pending | | Coinbase National Trust Company | — | Apr 2, 2026 | Pending | Pre-opening | | Laser Digital (Nomura) | De novo | May 29, 2026 | Pending | Pre-opening | | Payoneer | — | Filed Feb 24, 2026 | — | Application pending | | Zerohash | — | Filed Mar 4, 2026 | — | Application pending | | World Liberty Trust Company N.A. | De novo | Aug 14, 2026 | Pending | Pre-opening | | Wise National Trust | — | — | — | Denied Jul 30, 2026 |
Three of the original five December approvals — BitGo, Fidelity, and Paxos — are converting from state trust company charters to national trust bank charters. Of the five applicants, three (BitGo, Fidelity, and Paxos) intend to issue stablecoins under their new charters.
Protego represents a special case: it received conditional approval in 2021, failed to meet conditions before expiration, and received conditional re-approval in February 2026.
World Liberty Trust Company's approval took 220 days from filing to conditional approval — the slowest of the OCC's crypto approvals, according to CryptoTimes. The entity is linked to World Liberty Financial, in which an affiliate of President Trump and certain family members holds a reported 38% ownership stake. The bank is purpose-built for USD1 stablecoin operations; USD1 has reached over $4 billion in circulation.
A national trust bank charter provides three structural advantages over state-level money transmitter licenses:
Federal preemption. A single federal charter supersedes the patchwork of 50 state regulatory regimes. Coinbase, for example, currently operates under multiple state licenses. A federal charter consolidates supervision under one regulator.
Qualified custodian status. Under federal banking law, a national trust bank is automatically a qualified custodian — a designation institutional allocators require before placing assets. Forbes reported Coinbase's approval as relevant to its "$376 billion institutional custody empire."
Federal legitimacy. The OCC charter carries reputational weight with institutional counterparties, insurance providers, and prime brokers that state-level licenses do not.
What the charter does not deliver: access to the Federal Reserve discount window, FDIC deposit insurance, or a Federal Reserve master account. These require separate approvals. National trust banks supervised by the OCC currently number approximately 60, holding nearly $2 trillion in custody accounts.
Tier 1 capital requirements for these institutions range from $6.05 million to $25 million, according to OCC filings.
The Bank Policy Institute (BPI), a trade group representing roughly 40 major U.S. lenders including JPMorgan, Goldman Sachs, Citigroup, and American Express, has retained outside counsel to potentially sue the OCC. As of August 2026, no suit has been filed, but the legal arguments are public.
BPI's case rests on four pillars:
Administrative Procedure Act (APA) violations. BPI argues the OCC substantially changed licensing rules through interpretive letters and wording revisions, bypassing formal rulemaking procedures — specifically notice-and-comment requirements under the APA.
Competitive asymmetry. Traditional banks contend crypto firms gain federal payment system access and national bank credibility without carrying equivalent regulatory costs — deposit insurance assessments, Community Reinvestment Act obligations, and comprehensive capital adequacy standards.
Charter arbitrage. A limited-purpose trust charter now delivers bank-like national powers under a lighter regulatory framework, which BPI characterizes as a structural advantage unavailable to incumbent banks.
Scope creep. BPI argues the OCC reinterpreted what a trust company may do beyond statutory authority, particularly through the April 1 rule change.
Senator Elizabeth Warren has separately pressed the OCC on "approval of special charters for crypto companies seeking to act like banks while evading bank rules," according to the Senate Banking Committee's public statements. The Independent Community Bankers of America and National Community Reinvestment Coalition have also criticized the approvals.
Comptroller Gould has responded that his job is not about "incumbent protection" but about "preserving the integrity of the banking system."
Anchorage Digital Bank received the first federal crypto bank charter from the OCC in January 2021. Five years later, it remains the template for what a crypto-native bank can become.
In February 2026, Tether invested $100 million in Anchorage, valuing the company at $4.2 billion. On June 22, 2026, Anchorage launched a tokenized deposit infrastructure platform — a B2B layer enabling licensed U.S. banks to issue and manage on-chain deposit tokens with 24/7 settlement. The platform provides smart contract infrastructure, wallet and key custody APIs, mint and burn endpoints, and blockchain analytics.
Anchorage has also launched what it calls "Agentic Banking" — infrastructure enabling AI agents to transact within a governed framework.
The fact that only Anchorage and Circle have reached full operational status underscores the gap between conditional approval and actual banking operations. Conditional approval does not permit a proposed bank to begin business; applicants must satisfy capital, governance, compliance, and operational requirements and pass a pre-opening OCC examination.
On March 4, 2026, the Federal Reserve Bank of Kansas City approved a limited-purpose master account for Kraken Financial, the Wyoming-chartered banking arm of Kraken. This made Kraken the first crypto firm to access the Fed's core payment systems directly.
The master account enables Kraken to settle U.S. dollar transactions on Fedwire, bypassing intermediary correspondent banks. However, the approval is limited in scope: Kraken does not have access to the discount window or interest on reserve balances. The account has an initial term of one year and carries conditions traditional banks do not face. Industry analysts have characterized it as a test of a "skinny" master account concept.
Kraken's path — a Wyoming special-purpose depository institution plus a Fed master account — represents an alternative to the OCC national trust bank charter route. Both paths lead toward the same destination: direct integration of crypto firms into the federal financial infrastructure.
Not every applicant succeeds. The OCC denied Wise National Trust's application on July 30, 2026, citing "significant supervisory and compliance concerns including longstanding deficiencies in anti-money laundering and counter-terrorist financing controls in the US."
Less than a month after filing its original application in June 2025, Wise's U.S. subsidiary received a multistate consent order documenting AML deficiencies, including late Suspicious Activity Report filings, transaction monitoring data integrity issues, and a missing independent compliance program review. Wise shares fell as much as 11% on the denial.
Wise has indicated it plans to refile under the GENIUS Act framework. The denial serves as a counterpoint to claims that the OCC is simply opening federal charters to every applicant — the agency's stated standard remains "a reasonable chance of success," not a rubber stamp.
The charter wave restructures how economic value flows through the crypto ecosystem. Under the previous model, crypto firms paid intermediary banks for access to payment rails, custody infrastructure, and compliance cover. Each layer extracted rent.
Under the charter model, firms internalize those functions. A company like Coinbase, holding a national trust bank charter, no longer needs a bank partner for institutional custody. Circle, now operating as First National Digital Currency Bank, manages USDC reserve operations under direct federal supervision rather than through a banking relationship.
The shift creates a new cost structure. Charter holders bear direct regulatory costs — OCC supervision fees, examination cycles, capital requirements — but eliminate correspondent banking fees and intermediary margins. For firms processing billions in daily volume, the economics favor internalization.
The downstream effect on traditional banks is measurable: the banking lobby's legal mobilization reflects a calculation that charter-holding crypto firms will capture custody, payment, and stablecoin revenue that currently flows through incumbent bank balance sheets.
The OCC charter wave is not a regulatory favor to the crypto industry. It is the formalization of a sector that previously operated in regulatory ambiguity. The 40 applications in 18 months represent a market judgment: firms with sufficient capital, compliance infrastructure, and operational capacity have concluded that federal bank status is worth the supervisory burden.
The unresolved question is legal. If the Bank Policy Institute files suit, the scope of what a national trust bank charter permits will be adjudicated in federal court. The outcome will determine whether the current wave of approvals represents a permanent structural shift or a regulatory interpretation subject to reversal.
For now, the data is clear: crypto firms are entering the federal banking system at a pace not seen in any sector since community bank formation peaked in the early 2000s. Whether they stay depends on whether the legal and regulatory framework built in the last eight months survives the challenge from the institutions it was designed to bypass.