A national trust bank charter can let a crypto company operate a federally chartered bank limited to trust-company operations and related activities. That can include fiduciary or non-fiduciary custody and, where the OCC permits them as related services, activities such as customer-directed execution or staking. It is not a blanket license to run any crypto business or a full-service commercial bank. The institution’s actual authority depends on its charter, approved business plan, conditions, and other applicable law.
What the charter is—and what it is not
Under 12 U.S.C. § 27(a), the OCC may charter a national bank limited to “those of a trust company and activities related thereto.” This is a federal bank charter with a restricted business scope, not simply a state trust-company label and not the same as permission to conduct every activity available to a general-purpose bank.
The OCC’s Interpretive Letter 1176 treats trust-company operations as including both fiduciary work and non-fiduciary services such as custody and safekeeping. A company therefore does not have to act as a trustee in every customer relationship for an activity to fit within the trust-company framework. But whether a specific service fits is an OCC and institution-specific question; calling a product “custody” does not by itself establish its legal status.
The OCC’s February 27, 2026 final rule, effective April 1, 2026, amended 12 C.F.R. § 5.20 to refer to trust-company operations and related activities. The OCC said the rule neither expanded nor contracted its authority to charter a national bank. It clarifies that a trust-company-limited national bank may conduct non-fiduciary activities as well as fiduciary ones; it does not turn the limited-purpose charter into a general banking license.
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Which crypto activities may fit
Custody and safekeeping
OCC materials recognize custody and safekeeping of digital assets as activities that can fall within trust-company operations. Custody may be fiduciary or non-fiduciary depending on the arrangement and the bank’s role. If it is fiduciary, the bank remains subject to the applicable fiduciary requirements in 12 U.S.C. § 92a and 12 C.F.R. Part 9. Letter 1176 did not remove those obligations or redefine fiduciary capacity.
Services connected to custody accounts
The OCC has described some customer-directed execution, trading, and settlement-related functions as potentially permissible when tied to custody accounts. In a 2025 statement, it said national banks may buy and sell assets held in custody at a customer’s direction and may outsource bank-permissible custody and execution activities, subject to appropriate third-party risk management and safe, sound operations. That is not a determination that every trading service, token, or outsourcing arrangement is permissible.
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Staking and other ancillary services
A 2026 OCC decision concerning Fidelity Digital Assets discusses staking as an ancillary custody service previously allowed in particular cases, as well as trading-related services connected to customers’ custody accounts. Those examples describe agency treatment of specific proposed activities; they do not approve every staking model or make staking an automatic feature of every national trust bank charter.
Stablecoin-related functions
OCC materials address reserve-related functions, but a trust bank charter alone does not authorize every stablecoin issuance or reserve-management model. In its preliminary conditional approval for Ripple National Trust Bank, the OCC considered a proposed business that included directed management of liquid assets backing an affiliate’s stablecoin. That scope belongs to that proposal and its conditions, not to all charter holders.
What it does not automatically allow
The charter does not, by itself, authorize a company to offer every crypto product, financial service, or commercial banking function. The governing limit is trust-company operations and activities related to them. Whether a particular product falls within that boundary depends on the approved activities and applicable law; the OCC materials do not provide a universal list of products that every trust bank may or may not offer.
Do not infer ordinary deposit-taking, lending, retail banking, or deposit insurance from the word “bank.” The Ripple proposal, for example, was identified by the OCC as an uninsured national trust bank. That fact does not establish the insurance status or deposit powers of other institutions; those require institution-specific verification.
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Nor does a general OCC statement that a category of activity may be permissible settle whether a particular company can offer it. The company’s approved business plan, charter, fiduciary powers, conditions, operating controls, and other laws all matter. Where a third party performs a function, outsourcing does not remove the bank’s responsibility to manage the associated risks.
Application, conditional approval, and authority to open are different
An application is not an authorization. Preliminary conditional approval is also not final authority to commence business. In Ripple’s December 12, 2025 preliminary conditional approval, the OCC said final authorization would follow satisfaction of pre-opening requirements and reserved the ability to modify, suspend, or rescind the preliminary approval. As of that decision, the proposed institution could not treat conditional approval as permission to begin operations.
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The OCC lists pending digital-asset charter applications separately from final decisions. Its application list is time-sensitive: a pending entry does not mean the OCC has approved the charter, and an old status may no longer be current. Check the OCC’s current application and decision records before relying on a company’s stated status.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to assess a crypto company’s charter claims
- Confirm the status. Determine whether the firm is an applicant, has preliminary conditional approval, or has final authorization to open.
- Read the institution-specific scope. Identify the services named in its charter decision and approved business plan rather than assuming another trust bank’s permissions carry over.
- Classify the relationship. Establish whether the service is fiduciary or non-fiduciary; fiduciary activity brings the relevant Part 9 requirements.
- Check the connection to trust operations. For non-fiduciary services, look for how the OCC decision ties the activity to custody, safekeeping, or another trust-company function.
- Review conditions and risk arrangements. Note pre-opening requirements, operating limits, customer direction, and any third-party roles or risk controls.
- Verify other legal requirements. OCC charter authority does not answer every question about a product, customer relationship, or applicable law.
What the OCC’s figures say about trust banks
The OCC reported that, as of September 30, 2025, OCC-supervised uninsured national trust banks held $6.8 trillion in assets under administration: $1.6 trillion in custody and safekeeping accounts and $5.2 trillion in fiduciary accounts. These are aggregate figures for the supervised trust-bank sector, not crypto-specific assets or balances held by any one crypto company.
How the rules changed
In 2021, OCC Interpretive Letter 1179 discussed a supervisory non-objection process for certain crypto activities. The OCC’s March 2025 interpretive index says Letter 1183 rescinded that process. The index also reaffirmed the permissibility of crypto custody, holding deposits that back stablecoins, and using distributed ledger technology and stablecoins for otherwise permissible payment activities. Those statements concern national-bank authority generally; a trust-company-limited charter remains confined to its narrower trust-operation scope. The 2026 rule is the current OCC clarification on that charter category.
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