Between December 12, 2025 and March 5, 2026 — a span of 83 days — eleven companies filed for or received conditional approval for OCC national trust bank charters. The Office of the Comptroller of the Currency had averaged fewer than four charter applications per year between 2011 and 2024. In th...
"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 Gould, Comptroller of the Currency, OCC
Between December 12, 2025 and March 5, 2026 — a span of 83 days — eleven companies filed for or received conditional approval for OCC national trust bank charters. The Office of the Comptroller of the Currency had averaged fewer than four charter applications per year between 2011 and 2024. In that 83-day window, the OCC processed more crypto-related charter activity than the prior decade combined.
Eight firms have received conditional approvals: Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos (December 2025), then Stripe's Bridge, Crypto.com, and Protego (February 2026). Three more applications — Morgan Stanley Digital Trust, Payoneer, and Zerohash — are pending. World Liberty Financial, the Trump-linked DeFi protocol, filed separately in January 2026 and remains under review. Only one crypto-native firm, Anchorage Digital Bank, has completed the transition from conditional approval to a fully operational final charter.
The Bank Policy Institute, a trade group 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 banking lobby argues that the agency has reinterpreted federal licensing rules to let crypto firms access the federal banking system under lighter oversight than fully chartered banks. No formal legal action has been filed as of March 20, 2026. The outcome of this confrontation will determine whether crypto custody and stablecoin infrastructure operates inside or outside the U.S. banking perimeter.
The timeline of OCC charter activity since December 2025:
Wave 1 — December 12, 2025 (Conditional Approvals):
Wave 2 — February 2026 (Conditional Approvals):
Pending Applications:
Of the Wave 1 approvals, three firms — BitGo, Paxos, and Fidelity — intend to issue stablecoins. Circle issues USDC through a separate New York limited purpose trust company. Ripple issues RLUSD through an equivalent structure. Crypto.com's charter focuses on institutional trade settlement, multi-chain staking, and digital asset custody.
Comptroller Gould told the U.S. Senate that the OCC received fewer than four charter applications per year on average between 2011 and 2024. Fourteen de novo applications were filed in 2025 and 2026 alone, according to Gould's testimony at a Blockchain Association conference.
A national trust bank charter grants a single federal regulatory framework under OCC supervision. It does not grant FDIC insurance, access to the Federal Reserve's payment rails, or permission to accept retail deposits, offer checking or savings accounts, or make loans.
Chartered entities can provide: custody of digital and traditional assets, fiduciary staking and validation, trade execution, transfer agent services, stablecoin issuance and redemption (subject to GENIUS Act compliance), settlement, clearing, and escrow services.
The distinction matters. These are not banks in the consumer-facing sense. They are regulated infrastructure providers — custodians, settlement engines, and stablecoin operators — operating under federal supervision. The charter provides institutional legitimacy and a single-regulator framework that replaces a patchwork of state-by-state licensing.
Fed Governor Chris Waller has said publicly that he is exploring a streamlined account structure for newly chartered entities. No formal framework for Fed payment rail access exists yet, according to FinTech Weekly reporting.
The charter sprint did not happen in a vacuum. The OCC systematically cleared the regulatory path.
Interpretive Letter #1176 (2021): Authored by Jonathan Gould when he was OCC general counsel, the letter authorized firms with trust charters to engage in non-fiduciary activities such as asset custody. This letter became the legal foundation for the current wave.
SAB 121 Rescission: The SEC's SAB 121, which required banks to record custodied crypto assets as liabilities on their balance sheets, was rescinded and replaced by SAB 122. This removed a significant accounting obstacle to bank-held crypto custody.
OCC Final Rule (Effective April 1, 2026): Published in the Federal Register on March 2, 2026, the rule replaces the term "fiduciary activities" with "operations of a trust company and activities related thereto" in 12 CFR 5.20. The effect is to explicitly confirm that national trust banks may conduct non-fiduciary activities, including crypto custody, stablecoin management, and settlement services.
Each of these changes expanded the charter's functional scope. Taken together, they transformed the national trust bank from a narrow fiduciary vehicle into a broad digital asset infrastructure license.
The digital asset custody market is projected to grow from $3.69 billion in 2026 to $7.74 billion by 2032, according to 360iResearch, reflecting a 13.05% compound annual growth rate. Grand View Research estimates a larger market definition reaching $4.38 trillion by 2033. Capco projects assets under custody exceeding $16 trillion by 2030.
The variance reflects different definitions of "custody market" — from fee revenue to assets under management — but the directional signal is consistent: custody is where the margin lies in institutional crypto.
Current competitive standings, per Agio Ratings' Q1 2026 institutional risk assessment:
| Custodian | Default Probability | Key Differentiator | |-----------|--------------------|--------------------| | Fidelity Digital Assets | 0.39% | OCC charter, $4T+ parent backing | | Anchorage Digital | 0.46% | Only final-charter crypto bank | | BitGo | Not disclosed | OCC charter, NYSE-listed (BTGO) | | Coinbase Custody | Not disclosed | 12% of total crypto market cap | | Fireblocks | Not disclosed | MPC-based infrastructure layer |
BitGo became the first publicly traded, federally chartered digital asset infrastructure company when it listed on the NYSE on January 22, 2026. The IPO raised $212.8 million at $18 per share, with Goldman Sachs as lead bookrunner and Citigroup as co-bookrunner. The offering was approximately 13 times oversubscribed. BitGo reported revenue growth from $1.9 billion to $10 billion year-over-year for the first nine months of 2025, with assets under custody crossing $90 billion in mid-2025.
Approximately 48% of custody clients now hold both cryptocurrencies and tokenized securities within unified custody platforms, according to industry data — a convergence that makes the charter's broad scope strategically important.
The Bank Policy Institute (BPI), whose members include JPMorgan Chase, Bank of America, Citigroup, Wells Fargo, Goldman Sachs, Santander, and HSBC, is considering filing a lawsuit against the OCC, according to reporting by The Guardian and The Block.
The core argument: the OCC has reinterpreted federal licensing rules to allow crypto and fintech firms to operate under the federal banking seal of approval without subjecting them to the same capital requirements, compliance burdens, and supervisory rigor as full-service banks.
BPI stated in December 2025: "Today's decision by the OCC to grant conditionally five national trust charters leaves substantial unanswered questions. Chiefly, whether the requirements the OCC has outlined for the applicants are appropriately tailored to the activities and risks in which the trust will engage."
The American Bankers Association (ABA) has raised separate concerns about naming standards and consumer confusion — specifically, whether limited-purpose trust entities should be permitted to use the word "bank" in their names.
The Conference of State Bank Supervisors has argued that the OCC is assembling charter structures beyond what the National Bank Act permits, effectively creating a new category of federally supervised institution without explicit congressional authorization.
Standard Chartered analysts estimated that stablecoin provisions under the GENIUS Act, combined with trust bank charters, could redirect up to $1 trillion in deposits away from traditional banks toward stablecoin products by 2028.
No formal legal action has been filed as of March 20, 2026. BPI has declined to comment publicly on its litigation timeline.
Morgan Stanley's February 18 filing for Morgan Stanley Digital Trust, N.A. signals a structural shift: Wall Street is moving crypto custody from outsourced relationships to in-house operations.
The proposed entity would handle direct crypto custody, fiduciary staking, and token trading from its headquarters in Purchase, New York. This is not a trading desk. According to PYMNTS, it is a bid to own the "custody, settlement and fiduciary plumbing layer of blockchain finance under U.S. bank supervision."
Morgan Stanley is building a vertically integrated crypto value chain:
The comment period for Morgan Stanley's application closes March 20, 2026. If approved, Morgan Stanley would become a direct competitor to crypto-native custodians such as BitGo, Anchorage, and Coinbase Custody.
Zerohash, Morgan Stanley's infrastructure partner, filed its own OCC application on March 5. Zerohash raised $104 million at a $1 billion valuation in September 2025, with Interactive Brokers leading and Morgan Stanley participating. By January 2026, Zerohash was in talks to raise $250 million at a $1.5 billion valuation. Zerohash already provides crypto infrastructure to Morgan Stanley, Interactive Brokers, Stripe, Franklin Templeton, Kalshi, and BlackRock. In October 2025, Mastercard entered late-stage talks to acquire Zerohash for up to $2 billion; Zerohash walked away, choosing independence.
The charter race reshapes how economic value flows through the crypto ecosystem.
Cost compression for institutions. Under the current model, institutional crypto transactions route through a patchwork of state-licensed custodians, each with separate compliance overhead. A single federal charter eliminates duplicative licensing costs. For firms like Zerohash, which currently holds multiple state and international licenses, consolidation under one regulator reduces operational drag.
Custody as the margin layer. BitGo's revenue trajectory — from $1.9 billion to $10 billion in nine months — demonstrates that custody and settlement infrastructure, not trading, is where institutional crypto generates sustainable revenue. This aligns with the broader observation that on-chain fee revenue (approximately $13.7 billion annually across the ecosystem) remains a fraction of total value flows. Infrastructure providers that capture custody, settlement, and staking fees are building the closest thing to recurring revenue in crypto.
Stablecoin issuance as a charter driver. Three of the original five approved firms intend to issue stablecoins. The GENIUS Act, which requires stablecoin issuers to maintain strict reserve backing in cash and short-dated Treasuries, makes a national trust bank charter a natural compliance vehicle. Supervisory agencies must publish implementing rules by July 18, 2026, with regulations taking effect six months later. The charter race is partly a race to be positioned before those rules lock in.
The $1 trillion deposit migration risk. Standard Chartered's estimate that trust-bank-chartered stablecoin issuers could redirect $1 trillion in deposits from traditional banks by 2028 explains the banking lobby's intensity. If stablecoins backed by Treasuries offer comparable safety to bank deposits but with programmability, instant settlement, and cross-border functionality, the competitive pressure is structural, not temporary.
The OCC's 83-day charter sprint created, in effect, a new category of federally supervised financial institution: the crypto-native national trust bank. Whether it survives legal challenge from the banking lobby and political scrutiny over entities like World Liberty Financial will determine the shape of U.S. digital asset infrastructure for the next decade.
The economic logic is straightforward. Custody, settlement, and stablecoin issuance are the plumbing layers of institutional crypto. Whoever controls that plumbing under federal supervision controls the highest-margin, most defensible position in the value chain. The OCC has opened the door. The question is whether it stays open.