Eleven companies filed for or received conditional approvals for national trust bank charters from the U.S. Office of the Comptroller of the Currency (OCC) in an 83-day window between December 12, 2025, and March 5, 2026. The applicants span crypto-native firms (Coinbase, Ripple, Circle, Paxos, B...
"This charter is about bringing federal regulatory uniformity to the custody and market infrastructure business we have been building for years." — Coinbase, in a statement accompanying its OCC conditional approval announcement, April 2, 2026
Eleven companies filed for or received conditional approvals for national trust bank charters from the U.S. Office of the Comptroller of the Currency (OCC) in an 83-day window between December 12, 2025, and March 5, 2026. The applicants span crypto-native firms (Coinbase, Ripple, Circle, Paxos, BitGo, Crypto.com, Protego), fintech infrastructure providers (Bridge, Zerohash, Payoneer), and a Wall Street incumbent (Morgan Stanley). Coinbase received its conditional approval on April 2, 2026. EDX Markets, backed by Citadel Securities and Charles Schwab, filed a separate application on March 25, 2026, bringing the total known applicants to at least 13.
The filing wave was enabled by an OCC rule change effective April 1, 2026, that replaced the term "fiduciary activities" with "operations of a trust company and activities related thereto" in 12 CFR 5.20. The amendment explicitly codified the OCC's position that national trust banks may conduct non-fiduciary custody — the precise service model crypto firms require. Traditional banking lobbies, led by the Bank Policy Institute (BPI) and the Independent Community Bankers of America (ICBA), have mounted legislative, regulatory, and potential legal opposition. BPI, whose board includes JPMorgan Chase CEO Jamie Dimon, Goldman Sachs CEO David Solomon, and Bank of America CEO Brian Moynihan, is weighing a lawsuit against the OCC.
The contest is no longer whether crypto firms will gain access to the U.S. banking system. It is on what terms, under what oversight framework, and whether the federal courts will permit it.
The coordinated rush to OCC charter applications unfolded in three distinct phases.
Phase 1 — December 12, 2025: The OCC conditionally approved five applications simultaneously. Ripple and Circle (filing as First National Digital Currency Bank) applied as de novo entities, building new national trust companies from scratch. BitGo, Fidelity Digital Assets, and Paxos applied as conversions from existing state trust companies to national trust bank status. This batch represented the first significant wave of crypto-focused national trust approvals since Anchorage Digital received its charter in January 2021.
Phase 2 — February 2026: Three additional conditional approvals followed in rapid succession. Bridge, Stripe's stablecoin infrastructure subsidiary, was approved around February 12. Protego received approval in early February — notably its second attempt, as its original 2021 conditional approval expired unused. Crypto.com was approved on February 23.
Phase 3 — Late February to March 2026: Three more entities filed applications. Morgan Stanley submitted on February 18, proposing Morgan Stanley Digital Trust National Association — making it the first major Wall Street bank to apply for a dedicated crypto custody entity under this charter structure. Payoneer filed on February 24. Zerohash filed on March 5.
Coinbase received its conditional approval on April 2, 2026, for Coinbase National Trust Company, a de novo non-insured national trust company to be headquartered in New York. CEO Brian Armstrong stated that the company is "not becoming a bank" but rather bringing its existing custody infrastructure under federal regulatory oversight.
Separately, EDX Markets, backed by Citadel Securities, Fidelity Digital Assets, Charles Schwab, Virtu Financial, Paradigm, Sequoia Capital, Hudson River Trading, and Miami International Holdings, filed its application on March 25, 2026, to charter EDX Trust, National Association, in Chicago.
To date, Anchorage Digital Bank remains the only entity to have progressed from OCC conditional approval to fully operational national trust bank status.
The regulatory foundation for the filing wave was laid by an OCC rulemaking published in the Federal Register on March 2, 2026, and effective April 1, 2026.
The amendment changed one phrase in 12 CFR 5.20: it replaced "fiduciary activities" with "operations of a trust company and activities related thereto," aligning the regulatory text with the statutory language of 12 U.S.C. 27(a).
According to the OCC's rulemaking statement, the agency had never interpreted "fiduciary activities" as limiting national trust banks to fiduciary services only. Non-fiduciary custody accounts — digital asset safekeeping, stablecoin reserves custody, and institutional asset management without discretionary authority — were considered permissible under existing authority. The amendment codified this interpretation, removing textual ambiguity that opponents could have challenged in court under a future administration with different regulatory priorities.
The practical effect: a national trust bank can now operate custody, safekeeping, and related services as its primary business model, not merely as an ancillary function to fiduciary activities. This is the precise operating model that crypto custodians require.
The timing was deliberate. By formalizing the rule before the GENIUS Act or CLARITY Act reached final passage, the OCC locked in a regulatory framework that exists independent of stablecoin legislation.
A national trust bank charter under the OCC grants several specific authorities:
Permitted activities: Custody and safekeeping of digital assets in a fiduciary or non-fiduciary capacity. Operation as a qualified custodian under SEC regulations. Stablecoin reserve custody. Institutional settlement services.
Not permitted: Deposit-taking. Lending. Fractional reserve banking. Access to FDIC insurance. The charter entities are non-insured national trust companies, not commercial banks.
This distinction matters. These entities sit in a regulatory middle ground — more heavily supervised than state-chartered trust companies, but not subject to the full Bank Holding Company Act requirements that apply to FDIC-insured depositories. They face OCC capital standards, compliance reviews, and ongoing examination cycles, but are exempt from many prudential requirements that govern traditional banks.
The post-approval pathway is also demanding. To move from conditional to final approval, an applicant must hold an initial board meeting, formalize corporate bylaws, establish internal payment infrastructure, and pass a comprehensive pre-opening examination by OCC regulators. The examination covers security, compliance, risk management, and anti-money-laundering protocols. The fact that only Anchorage has completed this process in five years illustrates the difficulty.
A national trust bank charter does not automatically grant access to Federal Reserve payment infrastructure. This is a critical gap.
On March 4, 2026, Kraken Financial became the first digital asset firm to receive a Federal Reserve master account, approved by the Federal Reserve Bank of Kansas City. The account provides direct access to Fedwire and core Fed payment rails, enabling faster U.S. dollar settlement without reliance on correspondent banking relationships.
The Kraken approval is limited in scope. Kraken does not earn interest on reserves held at the Fed and has no access to discount window emergency lending — privileges reserved for traditional depository institutions. The arrangement is described as a "skinny" master account, a concept the Federal Reserve Board is developing as a potential framework for non-traditional financial institutions.
For the eleven OCC charter applicants, Fed payment access remains an open question. Without it, these entities still depend on correspondent banks for dollar settlement — the same intermediation they sought to bypass. The Custodia Bank case, which fought the Federal Reserve for master account access from 2022 through early 2026, concluded in March 2026, according to CoinDesk, just as the Fed opened its "skinny" master account framework.
The sequence is important: OCC charter first, Fed access second. The charter establishes the regulatory foundation. Whether and when each entity secures payment rail access will determine the economic viability of the model.
Opposition from incumbent banks has materialized along three fronts.
Front 1 — Regulatory: The Independent Community Bankers of America (ICBA) has opposed every significant charter approval. ICBA President and CEO Rebeca Romero Rainey called the Coinbase approval "a grave mistake that will only serve to put U.S. consumers at risk." ICBA's core argument: the OCC lacks statutory authority to expand non-fiduciary trust powers, and crypto firms are obtaining benefits of a federal bank charter without satisfying the full scope of banking regulation.
Front 2 — Legal: The Bank Policy Institute, representing approximately 40 major U.S. lenders, is considering filing a lawsuit against the OCC. BPI's board includes JPMorgan Chase CEO Jamie Dimon, Goldman Sachs CEO David Solomon, and Bank of America CEO Brian Moynihan. As of mid-April 2026, no lawsuit has been filed, but according to reporting by The Block, the industry group is actively assessing legal options. The legal theory centers on whether the OCC exceeded its statutory authority by granting charters to entities that do not engage in traditional trust or banking activities.
Front 3 — Legislative: The American Bankers Association formally rejected the White House's compromise stablecoin legislation on March 5, 2026, specifically objecting to yield provisions on stablecoins. Standard Chartered analysts estimated such provisions could redirect up to $1 trillion in deposits away from traditional banks toward stablecoin products by 2028. The CLARITY Act, which would define crypto asset classification, remains stalled in the Senate over three unresolved disputes, including stablecoin yield treatment.
The Conference of State Banking Supervisors described the charter structure as a "Franken-charter," warning it "may not survive a legal challenge." The ABA separately pressed the OCC to slow charter reviews, arguing that federal approval should not circumvent SEC, CFTC, or other federal agency jurisdiction.
The filing wave reflects competition for a custody market that research firms estimate at $834 billion to $1.05 trillion in assets under custody globally for 2026, depending on methodology. The narrower custody services provider market — revenues from custody fees, not assets held — was estimated at $3.69 billion for 2026 by Research and Markets.
The economic logic for applicants is straightforward. A federal charter provides: nationwide operational authority without state-by-state licensing; qualified custodian status under SEC rules, required by institutional allocators; regulatory credibility that enables prime brokerage and settlement relationships; and a foundation for stablecoin issuance and reserve custody under the expected GENIUS Act framework.
For traditional finance entrants like Morgan Stanley and EDX Markets, the charter separates custody from brokerage and exchange functions — a market structure principle that traditional equities and derivatives markets follow but crypto markets have largely ignored. EDX explicitly stated that its trust entity "aims to introduce an operating model aligned with traditional financial market structure, enhancing transparency, reducing conflicts of interest and strengthening market resilience."
This structural separation matters for institutional adoption. Vertically integrated platforms that combine exchange, brokerage, and custody functions create concentration risk that institutional risk committees flag. A federally regulated, structurally independent custodian reduces that concern.
World Liberty Financial, the crypto venture linked to the Trump family, filed a de novo application for World Liberty Trust Company, National Association, in January 2026. The proposed entity would issue and custody the USD1 stablecoin and serve institutional customers including exchanges, market makers, and investment firms.
The application has generated scrutiny over potential conflicts of interest, given President Trump's family ownership stake in the company. Senator Elizabeth Warren sought to delay the charter process over these ties and was rebuffed. OCC Comptroller Jonathan Gould stated in February 2026 that he would follow the normal application process and would consider sharing the unredacted application with Senate Banking Committee leadership, including Chairman Tim Scott and Ranking Member Warren.
The World Liberty Financial application complicates the broader charter narrative. Critics argue it illustrates the risk of regulatory capture — that a permissive chartering environment may benefit politically connected applicants. Proponents counter that applying the same standard to all applicants, regardless of political affiliation, is the appropriate regulatory posture. The application's outcome will be watched as a signal of the OCC's institutional independence.
Several critical questions remain open:
Federal Reserve access policy. The "skinny" master account framework used for Kraken has not been formalized into a standing policy. Whether and when other charter holders gain Fed payment access remains at the discretion of individual Reserve Banks, creating geographic inconsistency.
BPI lawsuit. If filed, litigation could challenge the OCC's statutory authority to grant these charters, potentially freezing applications mid-process. A court injunction would create uncertainty for all conditional approvals that have not yet reached final status.
CLARITY Act and GENIUS Act. Both pieces of legislation remain in Senate negotiation. The interaction between stablecoin licensing frameworks and OCC trust charters is undefined. If the GENIUS Act creates a separate federal stablecoin licensing regime, the trust charter may become one of multiple paths to stablecoin issuance — or the preferred one.
International reciprocity. No framework exists for mutual recognition between U.S. OCC trust charters and equivalent regimes in the EU (MiCA), Hong Kong, Singapore, or Japan. Cross-border custody operations will require parallel licensing in each jurisdiction.
Conversion timeline. The gap between conditional and final approval has historically been measured in years, not months. Anchorage remains the only entity to have completed the process. Whether the OCC accelerates its pre-opening examination pipeline for the current wave is unknown.
The 83-day filing wave represents the most concentrated integration of crypto-native infrastructure into the U.S. federal banking system since the OCC first signaled openness to digital asset charters in 2020. The applicant list — spanning crypto exchanges, stablecoin issuers, payment fintechs, and a Wall Street bank — demonstrates that the trust charter has become a consensus regulatory strategy across otherwise competing market participants.
The economic logic is clear. Institutional digital asset custody requires qualified custodian status, federal regulatory credibility, and operational consistency across 50 states. The national trust charter provides all three, without requiring deposit-taking or lending operations that would trigger full commercial banking regulation.
What the charter does not provide is equally important. Without FDIC insurance, these entities cannot take deposits. Without guaranteed Federal Reserve payment access, they remain dependent on correspondent banks. Without resolution of the pending BPI legal challenge, every conditional approval carries litigation risk.
The race for federal crypto banking licenses is a structural market event, not a regulatory novelty. It will determine which firms control the custody, settlement, and stablecoin infrastructure layer of U.S. digital asset markets. The outcome depends on factors beyond any applicant's control: the federal courts, the Federal Reserve Board, and a Congress that has yet to pass comprehensive crypto legislation.