Twelve crypto and fintech firms have filed for or received conditional Office of the Comptroller of the Currency (OCC) national trust bank charters since December 12, 2025 — a 112-day sprint that constitutes the largest wave of de novo federal banking applications in the digital asset sector. The...
"New entrants into the federal banking sector are good for consumers, the banking industry and the economy. They provide access to new products, services and sources of credit to consumers, and ensure a dynamic, competitive and diverse banking system." — Jonathan V. Gould, Comptroller of the Currency
Twelve crypto and fintech firms have filed for or received conditional Office of the Comptroller of the Currency (OCC) national trust bank charters since December 12, 2025 — a 112-day sprint that constitutes the largest wave of de novo federal banking applications in the digital asset sector. The most recent conditional approval went to Coinbase on April 2, 2026.
The applicants span crypto-native custodians (BitGo, Paxos, Coinbase), stablecoin issuers (Circle, Ripple), traditional finance incumbents (Morgan Stanley, Fidelity Digital Assets), payments processors (Payoneer, Bridge/Stripe), and infrastructure firms (EDX Markets, Zerohash, Crypto.com). They are competing for a federal charter that permits custody, settlement, and fiduciary services across all fifty U.S. states under a single regulator — without accepting retail deposits or making loans.
The race is not without friction. The Bank Policy Institute (BPI), whose board includes CEOs of JPMorgan Chase, Goldman Sachs, and Citigroup, has retained outside counsel and is reviewing legal options to challenge the OCC's charter grants. Meanwhile, the Federal Reserve granted Kraken Financial its first crypto-firm master account on March 4, 2026, opening Fedwire access and setting a precedent that remaining applicants will seek to replicate.
The national trust bank charter is a federal license governed by the OCC under 12 CFR 5.20. It authorizes entities to operate trust companies — institutions that hold, manage, and administer assets on behalf of clients — under national bank supervision.
Prior to the current wave, only one crypto-native firm held a fully operational OCC charter: Anchorage Digital Bank, which received conditional approval in January 2021 and reached full operational status after clearing a 2022 consent order related to anti-money-laundering compliance. As of 2026, Anchorage remains the only crypto firm to have completed the full journey from conditional approval to unrestricted operations.
The current wave began on December 12, 2025, when the OCC simultaneously announced conditional approvals for five entities: Circle, Ripple (de novo charters), and BitGo, Fidelity Digital Assets, and Paxos (conversions from existing state trust companies).
The following table tracks all known applications and conditional approvals since December 2025:
| Entity | Type | Date | Status | Backers/Notes | |--------|------|------|--------|---------------| | Circle | De novo | Dec 12, 2025 | Conditional approval | Stablecoin issuer (USDC) | | Ripple | De novo | Dec 12, 2025 | Conditional approval | XRP, RLUSD stablecoin | | BitGo | Conversion | Dec 12, 2025 | Conditional approval | Crypto custody incumbent | | Fidelity Digital Assets | Conversion | Dec 12, 2025 | Conditional approval | $4.9T parent AUM | | Paxos | Conversion | Dec 12, 2025 | Conditional approval | Stablecoin issuer (PYUSD partner) | | Bridge (Stripe) | De novo | ~Feb 12, 2026 | Conditional approval | Acquired by Stripe, 2024 | | Protego | Conversion | Early Feb 2026 | Conditional approval | Previously held conditional charter | | Crypto.com | De novo | Feb 23, 2026 | Conditional approval | Exchange/custody | | Morgan Stanley | Filed | Feb 18, 2026 | Pending | Morgan Stanley Digital Trust, NA | | Payoneer | Filed | Feb 24, 2026 | Pending | Payments processor | | Zerohash | Filed | Mar 4, 2026 | Pending | Crypto infrastructure/B2B | | Coinbase | Filed Oct 2025 | Apr 2, 2026 | Conditional approval | $300B+ assets on platform | | EDX Markets | Filed | Mar 25, 2026 | Pending | Citadel, Schwab, Fidelity, Virtu |
Eight firms have received conditional approval. Five applications remain pending. No firm from this wave has yet achieved full operational status.
Permitted activities:
Prohibited or excluded activities:
The charter structure creates what is effectively a regulated custody-and-settlement utility — a firm that holds assets and moves them, but does not take deposits or lend. This distinction matters for capital requirements, supervision costs, and the scope of services each firm can layer on top.
On February 27, 2026, the OCC filed an amendment to 12 CFR 5.20, published in the Federal Register on March 2. The amendment replaced the phrase "fiduciary activities" with "operations of a trust company and activities related thereto." It took effect April 1, 2026.
The change is narrow but consequential. The prior regulatory text could have been read to restrict national trust banks to fiduciary-only activities. The OCC stated it had never interpreted the rule that way and pointed to existing interpretive letters as evidence. But the textual ambiguity existed, and the BPI had flagged it as a potential legal vulnerability. The amendment eliminates the ambiguity, explicitly authorizing non-fiduciary custody — the primary activity that crypto trust bank applicants intend to conduct.
The timing was not coincidental. The rule became effective the same day Coinbase's conditional approval was announced, and the same day Ripple's charter pathway became formally unambiguous.
Coinbase received conditional OCC approval on April 2, 2026, to establish Coinbase National Trust Company. The entity will operate as a non-insured national trust company focused on digital asset custody.
According to Chief Legal Officer Paul Grewal, "We still need final approval… our business will not operate under an OCC charter until we have that final approval. This next phase allows us to get into more detail on how we can extend our business."
The conditions require Coinbase to:
Coinbase currently serves as custodian for over 80% of U.S. digital asset ETFs. The company reported approximately $300–425 billion in assets on its platform as of early 2026. A federal charter would allow the firm to diversify revenue beyond trading fees toward steadier institutional custody income — a strategic shift as exchange fee compression accelerates across the industry.
The applicant field is not limited to crypto-native firms. Morgan Stanley filed on February 18, 2026, to establish Morgan Stanley Digital Trust, National Association — a wholly owned subsidiary of Morgan Stanley Capital Management. The proposed entity would provide custody of digital assets, facilitate buying, selling, swapping, and transferring tokens, and offer staking services on a fiduciary basis.
According to reporting from PYMNTS.com, Morgan Stanley's play is "less 'Morgan Stanley is launching a crypto exchange' and more 'Morgan Stanley is trying to own the custody, settlement and fiduciary plumbing layer of blockchain finance under U.S. bank supervision.'" The bank is building a vertically integrated institutional crypto stack: a retail trading platform, trust bank charter, spot ETFs across Bitcoin, Ethereum, and Solana, and the custody infrastructure to support all of it.
EDX Markets, backed by Citadel Securities, Charles Schwab, Fidelity Digital Assets, Virtu Financial, Paradigm, Sequoia Capital, and Hudson River Trading, filed on March 25, 2026, to establish EDX Trust, National Association. The proposed bank would serve exclusively institutional clients with custody, clearing, settlement, and risk management services. Its application is pending as of April 3.
The Bank Policy Institute, representing the largest U.S. banks, has retained outside counsel and is reviewing legal options to challenge the OCC's charter grants. BPI has not filed a lawsuit and has not made a final decision on whether to proceed.
The BPI's objections center on two arguments:
Scope creep: BPI contends the OCC is applying the national trust bank framework beyond its traditional limits, particularly regarding stablecoin reserve management and payment services that should face broader supervisory and consumer-protection requirements.
Procedural challenge: BPI has flagged OCC Interpretive Letter 1176 as having expanded charter eligibility without formal notice-and-comment rulemaking — a potential Administrative Procedure Act vulnerability.
The OCC's February 27 rule amendment partially addresses the second concern by codifying interpretive guidance into regulation. Whether BPI proceeds with litigation may depend on whether additional approvals continue and whether the Fed extends master account access to more charter holders.
The OCC charter alone does not provide access to Federal Reserve payment rails. That requires a separate Fed master account — and the Fed has historically been reluctant to grant accounts to non-traditional institutions.
On March 4, 2026, Kraken Financial became the first crypto firm to receive Federal Reserve master account approval, gaining direct access to Fedwire, which handles over $4 trillion in daily fund transfers. The precedent is significant: it means crypto-chartered banks can, in principle, move dollars without intermediary banks.
The Fed is also developing a "skinny master account" framework for non-depository charters. Under the proposal, qualified fintech and crypto firms could access FedNow and Fedwire, but not FedACH. These accounts would earn no interest on reserves, have no access to emergency lending, and face strict daily balance limits of $500 million or 10% of total assets.
Major banking groups formally opposed the skinny master account concept in February 2026. The outcome of this policy debate will determine whether OCC-chartered crypto trust banks can operate as standalone financial utilities or remain dependent on correspondent banking relationships with incumbents.
The charter race restructures the custody value chain. Currently, crypto custody generates revenue through basis-point fees on assets under management, transaction fees for settlement, and premium pricing for institutional-grade security and compliance.
The crypto custody provider market grew from $3.28 billion in 2025 to an estimated $3.69 billion in 2026, according to industry research, with projections of $7.74 billion by 2032 at a 13.05% compound annual growth rate. Direct bank custody has replaced approximately 60% of third-party exchange reliance for U.S.-based hedge funds, according to 2026 industry surveys.
The economic logic for applicants is straightforward: a federal charter reduces regulatory overhead (one regulator instead of fifty state regulators), enables cross-state operations, provides credibility for institutional clients, and — if Fed access follows — eliminates the cost and counterparty risk of correspondent banking. For incumbents like Morgan Stanley and Fidelity, the charter consolidates custody, trading, and settlement into a single regulated entity, capturing fees at multiple points in the transaction chain.
The risk is equally clear. No conditional approval guarantees full operational status. Anchorage Digital took over a year to reach operations and then faced a consent order. Compliance buildout costs for national bank-level AML/KYC infrastructure are substantial. And without Fed access, the charter's payment utility remains constrained.
The OCC national trust bank charter wave is a structural shift, not a regulatory curiosity. Twelve firms — spanning crypto-native platforms, stablecoin issuers, Wall Street incumbents, and payments processors — are converging on the same federal license within the same four-month window. The charter grants them custody and settlement authority across fifty states under one regulator, without deposit-taking or lending.
The outstanding variables are execution risk (compliance buildout, pre-opening examinations) and infrastructure access (Fed master accounts, payment rail connectivity). If the remaining applicants clear these hurdles, the result is a parallel banking layer purpose-built for digital asset custody and settlement — regulated like a bank, constrained like a trust company, and positioned to capture institutional flows that currently route through fragmented state-licensed entities.
The BPI's potential litigation adds a legal overhang. But the OCC's April 1 rule change and the Kraken Fed precedent suggest the regulatory trajectory favors charter expansion, not contraction.