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Crypto companies apply to the Office of the Comptroller of the Currency (OCC), which reviews whether the proposed national trust bank has a permissible business plan, capable management, safe and sound operations, and the controls needed to meet supervisory expectations. A conditional approval is not permission to open: the company must complete its bank-in-organization requirements, meet its specific conditions, and receive final OCC authorization before beginning business.
What a national trust bank charter does—and does not—authorize
A national trust bank is a federally chartered bank with a limited trust-company business scope, not automatically a conventional retail or commercial bank. The OCC assesses the activities proposed in the application and may limit the bank to activities it finds permissible under its trust authority and related activities described in its approved business plan.
In its 2026 decision on Coinbase National Trust Company, the OCC considered a proposal centered on fiduciary digital-asset custody for primarily institutional clients, along with activities related to custody accounts. The decision is an example of what one applicant proposed and what the OCC addressed; it is not a blanket authorization for every crypto company or trust bank. Read the OCC’s Coinbase decision.
Do not infer from a trust charter alone that a company can offer ordinary checking or savings accounts, take general-purpose deposits, or make loans. In the Coinbase decision, the OCC said the proposed bank would not be an insured depository institution and that the Community Reinvestment Act did not apply to that applicant as a matter of law. Those statements describe the OCC’s analysis of Coinbase’s proposal and should not be generalized to every trust-bank application.
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How the OCC charter application process works
- Define the bank and its business plan. The applicant must explain the proposed trust-company activities, customers, operations, governance, and related services. The OCC may authorize only activities it finds permissible and can tie operations to the approved business plan and conditions.
- Submit an application to the OCC. The OCC’s Digital Assets Licensing Applications page lists applications involving digital-asset products or services and links to Corporate Applications Search (CAS) for case-specific records. The OCC publishes public portions of applications subject to public comment.
- Undergo review. The OCC’s Chartering, Organization and Structure unit assesses whether an application meets statutory standards and whether the proposed institution can comply with supervisory expectations. Relevant considerations include management competence, safe and sound operations, a viable path to profitability, and a robust, board-approved BSA/AML/OFAC compliance program with staff training. The OCC describes its process as “transparent, apolitical and nonpartisan”; that is the agency’s characterization of its own process. See the OCC’s de novo chartering overview.
- Receive an OCC decision. A decision may be conditional. Conditional approval is a preliminary step, not authorization to commence business.
- Meet the conditions and complete pre-opening work. The organizers must satisfy the requirements in their own decision letter, establish governance and policies, obtain required approvals, complete bank-in-organization requirements, and pass the OCC’s pre-opening process. Only after final OCC approval may the bank begin business.
The OCC says it seeks to decide complete applications within 120 days of receipt. That is the agency’s stated target, not a guarantee that an applicant will receive final approval or open within that period. The practical timeline depends on application completeness, review, conditions, and pre-opening work.
Why conditional approval is not the same as opening
The distinction matters because a conditional approval letter can set requirements that remain outstanding. Ripple National Trust Bank’s letter, for example, says the bank may not begin business until it has met bank-in-organization requirements and received final OCC approval. It also sets a minimum of $11.7 million in tier 1 capital for that applicant. That capital figure is a Ripple-specific condition, not a universal minimum for every national trust bank applicant. See Ripple’s conditional approval letter.
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For a company evaluating an application, the decision letter is therefore essential: it identifies the particular activities approved, the conditions to satisfy, and the remaining steps before opening.
Recent OCC decisions and application figures
| OCC record | What it establishes |
|---|---|
| December 12, 2025 announcement | The OCC announced conditional approvals for two de novo national trust banks—First National Digital Currency Bank and Ripple National Trust Bank—and conversion approvals for BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company. The announcement reported approvals, not that all five institutions had opened. OCC announcement. |
| Coinbase National Trust Company | The OCC’s CAS record lists receipt on October 3, 2025, and approval on April 2, 2026. The decision explains the custody-focused proposal and the activities considered for that bank. CAS application record. |
| De novo applications, January 2025–September 18, 2026 | The OCC reports 44 applications received, 27 approved, two denied, and one returned. These totals cover all de novo applications, not crypto applications alone. OCC de novo chartering page. |
| Charter applications, 2011–2024 | The OCC says it received fewer than four charter applications per year on average during this period, attributing the low number to its prior regulatory approach. That explanation is the OCC’s own characterization. OCC de novo chartering page. |
How to check an applicant’s status
Application lists and records can change. For a specific company, consult the OCC’s digital-assets licensing page and follow its link to CAS. Distinguish carefully between an application, conditional approval, final approval, and permission to commence business; those are different stages, and a headline saying “approved” may refer only to a conditional decision.
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1Fix the driver behind crashes, sound loss and screen glitches2Repair Windows errors before they cause bigger problems3Scan for outdated or missing drivers - takes under a minuteThe OCC’s 2025 announcement also illustrates two routes: a de novo charter creates a new national bank, while a conversion concerns an existing state-chartered trust company seeking national status. In either case, the approved activity scope and opening conditions depend on that applicant’s record and decision.
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