The Office of the Comptroller of the Currency has received 40 de novo charter applications since early 2025 and approved 21, while denying two. In a single week ending September 4, 2026, the agency conditionally approved both OpenReserve Bank — an a16z-backed blockchain-native full-service bank —...
"Preliminary conditional approval to charter a de novo national bank is a privilege our team does not take lightly. Supervision, safety and soundness, compliance, and customer confidence are not constraints on what we are building; they are the foundation of it." — Dee Choubey, Co-founder & CEO, OpenReserve
The Office of the Comptroller of the Currency has received 40 de novo charter applications since early 2025 and approved 21, while denying two. In a single week ending September 4, 2026, the agency conditionally approved both OpenReserve Bank — an a16z-backed blockchain-native full-service bank — and Revolut's U.S. national bank charter, bringing the cumulative count of crypto-adjacent federal bank charters to its highest level since the national banking system was established in 1863.
The charter wave divides into two tiers: national trust banks (limited-purpose licenses for custody, settlement, and fiduciary services) and full-service national banks (deposit-taking, lending, and Federal Reserve access). Nine crypto firms — including Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Coinbase, Bridge, Protego, and Crypto.com — hold conditional trust charters granted between December 2025 and April 2026. OpenReserve is the first crypto-native applicant to receive conditional approval for a full-service national bank charter, which includes FDIC deposit insurance eligibility and access to Fedwire.
The regulatory posture contrasts sharply with 2022-2024, when Operation Choke Point 2.0 effectively shut crypto firms out of banking relationships. The reversal is generating political friction: Senator Elizabeth Warren has accused Comptroller Jonathan Gould of granting "illegal" charters that let crypto companies "evade the fundamental safeguards and obligations that come with being a bank."
Since early 2025, the OCC has processed charter applications at a pace not seen in decades. Comptroller Jonathan Gould stated the agency aims to decide complete applications within 120 days of submission. The aggregate scorecard through September 2026:
| Metric | Count | |---|---| | De novo applications received | 40 | | Conditional approvals granted | 21 | | Applications denied | 2 | | Applications pending or returned | 17 | | Average decision timeline (target) | 120 days |
The two denials — Wise and Bunq — were based on specific deficiencies. Wise's application cited AML compliance gaps and management inexperience. Bunq's denial referenced insufficient experience in U.S. credit and banking regulation among proposed directors, inadequate capitalization support, and an incomplete profitability plan. Notable exceptions to the 120-day target include World Liberty Trust Company (221 days for conditional approval) and Bunq (212 days for denial).
An April 1, 2026 regulatory amendment enabled much of this activity. The OCC replaced "fiduciary activities" with "operations of a trust company and activities related thereto" in its chartering rules, clarifying the scope of permissible activities for national trust banks in the digital asset space.
The distinction matters for economic value distribution. The two charter types carry fundamentally different risk profiles, capital requirements, and revenue capabilities:
National Trust Bank Charter (Limited-Purpose)
Full-Service National Bank Charter
The trust charter cohort — Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Bridge, Protego, Crypto.com, and Coinbase — represents the custody and settlement layer. OpenReserve and Revolut represent the deposit-taking and lending layer. The economic difference is substantial: trust banks generate revenue from fees; full-service banks generate revenue from net interest margin, fees, and payment processing.
OpenReserve Bank, N.A. received preliminary conditional approval on September 2, 2026 (published September 3) for a de novo full-service national bank charter headquartered in Salt Lake City, Utah. Key parameters:
The proposed services include deposits and lending, payments and treasury services, tokenized deposit products, digital asset custody, and foreign correspondent banking. A wholly owned subsidiary will handle stablecoin issuance, custody, conversion, and payment of U.S. dollar-denominated reserve-backed stablecoins.
OpenReserve's stated value proposition targets the "Fedwire dead zone" — the roughly 22 hours per day when the Federal Reserve's payment rails are offline (nights, weekends, holidays). The company cites approximately $33 trillion in stablecoin settlement volume during 2025 and intends to capture settlement volume during off-hours through 24/7 atomic onchain settlement.
The 12% leverage ratio requirement signals the OCC's awareness of the risk profile. A traditional bank would face a 5% floor. The 240% premium reflects the novelty of the business model and the absence of historical loss data for blockchain-native banking.
Revolut received conditional OCC approval for a U.S. national bank charter on September 4, 2026, the same week as OpenReserve. Key terms:
Revolut must apply for Federal Reserve Bank stock and obtain FDIC deposit insurance before commencing operations. The charter approval places Revolut in a different category from its current U.S. operations, which run through banking-as-a-service partnerships.
Between December 2025 and April 2026, the OCC issued nine conditional approvals for national trust bank charters to crypto-native firms. A timeline:
| Company | Charter Type | Conditional Approval | Status | |---|---|---|---| | Circle (First National Digital Currency Bank) | Trust | Dec 2025 | Final approval July 10, 2026 | | Ripple National Trust Bank | Trust | Dec 2025 | Preopening | | BitGo | Trust (conversion) | Dec 2025 | Preopening | | Paxos | Trust (conversion) | Dec 2025 | Preopening | | Fidelity Digital Assets | Trust (conversion) | Dec 2025 | Preopening | | Bridge (Stripe subsidiary) | Trust | Feb 2026 | Preopening | | Protego | Trust | Feb 2026 | Preopening | | Crypto.com (Foris DAX) | Trust | Feb 2026 | Preopening | | Coinbase National Trust Company | Trust | Apr 2, 2026 | Preopening |
Circle is the only firm to have received final approval and commenced operations. First National Digital Currency Bank, N.A. (doing business as Circle National Trust) received its final charter on July 10, 2026, providing federally regulated custody for digital assets with plans to expand into USDC reserve management oversight.
The eleven-in-eighty-three-days application surge — from Circle and Ripple through Zerohash — represented the fastest concentration of crypto-related charter filings in OCC history.
The OCC is imposing elevated capital standards across crypto-adjacent charters:
| Entity | Charter Type | Min. Capital | Tier 1 Leverage (3yr) | |---|---|---|---| | OpenReserve | Full-service | $210M | 12% | | Revolut (US) | Full-service | $95M | 10% | | Traditional de novo bank | Full-service | Varies (~$20-50M) | 5% | | Trust charter cohort | Trust | Lower thresholds | N/A |
The elevated ratios — 10-12% versus the standard 5% — function as a risk buffer. The OCC's Corporate Decision #1389 (OpenReserve) and #1390 (Revolut) both cite the novel nature of the business models and the need for enhanced loss-absorption capacity during the initial operating period.
Senator Elizabeth Warren, ranking member of the Senate Banking Committee, sent a formal letter to Comptroller Gould in May 2026 characterizing the trust charter approvals as violations of the National Bank Act. Her principal arguments:
The OCC has not publicly responded to the specific legal claims. The political dimension adds uncertainty to the durability of these charters, particularly if the administration changes.
Two additional developments during the same week underscore the broader convergence of traditional finance and crypto infrastructure:
Standard Chartered: G-SIB Spot Crypto Trading in the UAE
On September 3, 2026, Standard Chartered ($993 billion in assets) launched institutional spot Bitcoin and Ether trading through its Dubai International Financial Centre (DIFC) entity. The bank is the first Global Systemically Important Bank (G-SIB) to offer deliverable spot crypto trading in the Gulf region. The service is integrated into Standard Chartered's existing electronic FX trading channels. Clients settle trades through their choice of custodian, including Standard Chartered's own digital asset custody solution (launched September 2024). Standard Chartered first offered institutional spot crypto trading through its UK branch in July 2025.
Coinbase: Single-Stock Perpetuals SEC Filing
On September 1, 2026, Coinbase filed notice registrations with the SEC for single-stock perpetual contracts: Form 1-N (Coinbase Derivatives, as a security futures exchange) and Form BD-N (Coinbase Financial Markets, as a limited-purpose broker-dealer). The filing classifies equity perpetual derivatives as security futures under the Commodity Futures Modernization Act of 2000, creating joint SEC-CFTC oversight. Coinbase already offers stock perpetual futures to eligible international customers (launched March 2026) with up to 10x leverage. CFTC approval and launch date for U.S. markets remain pending. The filing preceded a 10% increase in COIN share price on September 4.
The charter wave has three primary implications for economic value distribution in blockchain ecosystems:
1. Fee capture shifts from protocols to banks. A federally chartered crypto bank can bundle custody, settlement, lending, and stablecoin issuance under one regulatory umbrella. This consolidates fee streams that currently fragment across multiple DeFi protocols and service providers. The economic efficiency is real: one compliance framework, one capital base, one regulatory relationship. The cost is centralization.
2. The Fedwire arbitrage window is finite. OpenReserve's thesis depends on the Federal Reserve not extending Fedwire to 24/7 operations. The Fed has signaled interest in expanded hours for FedNow but has not committed to round-the-clock Fedwire. If it does, the onchain settlement premium compresses. If it does not, the 22-hour daily window represents a structural advantage for blockchain-native banks.
3. Stablecoin issuance consolidates into banks. As the GENIUS Act takes effect (target: January 18, 2027), stablecoin issuers face new federal requirements. Firms with national bank charters — Circle, OpenReserve, potentially others — hold a structural advantage over non-bank issuers. The $302 billion stablecoin market may increasingly route through entities under OCC supervision.
The 21 approved charters represent a regulatory bet: that bringing crypto firms inside the banking perimeter produces better outcomes than leaving them outside it. The counter-argument, articulated by Warren and others, is that the perimeter is being stretched to accommodate activities that do not fit. The data on which approach generates lower systemic risk does not yet exist.
The OCC's charter pipeline represents the most significant structural change to U.S. banking's relationship with crypto since the agency first clarified that national banks could custody digital assets in 2020. Twenty-one conditional approvals in 18 months have created a two-tier system: trust banks for custody and settlement, full-service banks for deposits and lending. The elevated capital requirements — 10-12% Tier 1 leverage versus 5% for traditional banks — reflect regulatory caution, not enthusiasm.
Whether these charters survive a potential change in administration, congressional scrutiny, and the operational reality of blockchain-native banking remains to be determined. The capital has not been fully raised. The preopening examinations have not been passed. Circle alone has crossed the finish line. The other 20 conditional approvals remain, for now, conditional.