A national trust bank charter is a federal, limited-purpose bank charter for trust company operations and activities related to them. For a crypto company, an OCC-approved charter can support services such as institutional digital-asset custody, fiduciary work as a collateral trustee, and related reserve management—but it is not blanket permission to run every kind of crypto or banking business.
What a national trust bank charter means
The Office of the Comptroller of the Currency (OCC) charters national banks under the National Bank Act, 12 U.S.C. §§ 21–27. Congress amended 12 U.S.C. § 27 in 1978 to confirm that a national bank may limit its operations to those of a trust company and activities related to them. In a February 2026 final rule, the OCC clarified that this authority covers both fiduciary and related non-fiduciary activities; the rule took effect April 1, 2026. OCC final rule, February 2026
Trust company operations are broader than managing property as a fiduciary. The OCC includes related non-fiduciary services such as custody and safekeeping. Whether a proposed service fits depends on the activity and the bank’s approved business plan—not simply on the fact that the company has a trust charter.
What a crypto company may be able to do
OCC decisions illustrate several possible services, subject to the facts and conditions of the specific application:
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- Digital-asset custody and safekeeping: Hold crypto assets for institutional clients or affiliates. The precise customer relationship and whether the bank acts in a fiduciary capacity depend on the approved arrangement.
- Collateral trustee services: Act in a fiduciary role for the benefit of stablecoin holders or other beneficiaries.
- Related reserve management: Manage liquid reserve assets on a directed basis when connected with a related trust or fiduciary service. This example does not establish general permission to issue stablecoins.
In its decision concerning Ripple, the OCC treated the proposed cryptocurrency custody, collateral trustee work, and associated reserve management as within the proposed bank’s trust company operations or related activities. That conclusion applies to the proposal before the agency; it is not blanket approval of the same products for every company. OCC decision concerning Ripple
Separately, the OCC’s March 2025 Interpretive Letter 1183 reaffirmed that certain activities involving crypto-asset custody, deposits backing stablecoins, and the use of distributed ledger technology or stablecoins for permissible payment activities can be permissible for national banks and federal savings associations. The letter addresses the activities within its legal analysis; it does not make every crypto activity automatically permissible. OCC Interpretive Letter 1183
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What the charter does not establish
A national trust bank charter should not be read as a general crypto license or as proof that the company can operate like a full-service commercial bank. The reviewed decisions establish trust and related activities, not blanket authority for every crypto product or for activities such as taking deposits from the public or making loans. The OCC’s final rule defines the scope around trust company operations and related activities, while each bank’s actual permissions depend on its decision and conditions. OCC final rule, February 2026
How to read an application or approval announcement
Regulatory status has distinct stages. The OCC evaluates applications individually, and approval can include conditions that must be met before the institution may proceed. In December 2025, the OCC announced conditional approvals for five national trust bank applications, stating that the institutions would join the OCC-supervised national trust banks subject to meeting OCC conditions. OCC announcement, December 2025
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For example, the OCC’s record for Coinbase National Trust Company lists approval on April 2, 2026. That is a dated status entry; it should not be conflated with an application, conditional approval, or consummation/effective status. The OCC’s digital-assets application list separately tracks applications and is updated as filings are received. OCC national trust bank records OCC digital-assets application list
When assessing a company’s claim, check the OCC record and decision for:
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- the proposed activity, such as custody, trustee work, or reserve management;
- whether the bank acts in a fiduciary or non-fiduciary capacity;
- whether the proposal is a new charter or conversion of an existing state trust company;
- the precise milestone reached: application received, conditional approval, approval, or consummated/effective; and
- the conditions and scope in the decision and approved business plan.
What OCC trust-bank figures do—and do not—show
The OCC reported $6.8 trillion in assets under administration at OCC-supervised uninsured national trust banks as of September 30, 2025: $1.6 trillion in custody and safekeeping accounts and $5.2 trillion in fiduciary accounts. These figures cover the overall population of those trust banks, not crypto banks alone. OCC 2025 Annual Report
In remarks published August 19, 2026, Comptroller of the Currency Jonathan V. Gould said 23 of 40 new bank charter applications involved some form of digital-asset activity. That is his count for the stated group and period, not a timeless share of all bank applications. OCC remarks, August 19, 2026
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