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A national trust bank charter is a federal charter for a national bank whose operations are limited to trust company business and activities related to it. For a crypto company, it can provide a path—subject to the Office of the Comptroller of the Currency’s (OCC) review, approval and conditions—to offer services such as institutional digital-asset custody, fiduciary trustee work and related reserve management. It is not a blanket license for every crypto business or proof that the company may take deposits or begin all planned activities.
What a national trust bank charter means
The 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 business to trust company operations and activities related to them. In a February 2026 final rule, the OCC clarified that this scope includes related non-fiduciary activities as well as fiduciary work. The rule took effect April 1, 2026. OCC rule and bulletin
“Limited purpose” does not mean that the bank can perform only traditional fiduciary asset management. The OCC describes trust company operations as including fiduciary services and related non-fiduciary services, including custody and safekeeping. The boundary is the charter, applicable law, the OCC’s decision and the bank’s approved business plan—not the broad label “crypto bank.”
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OCC decisions illustrate services that may fit within a national trust bank’s trust operations or related activities. The exact scope depends on the application and the regulator’s decision.
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Digital-asset custody and safekeeping
A national trust bank may be authorized to hold digital assets for institutional clients or affiliates. Whether the bank acts in a fiduciary or non-fiduciary capacity, and which assets and customer relationships are covered, depends on the approved plan and conditions. OCC Interpretive Letter 1183
Fiduciary trustee services
A bank may act as a collateral trustee in a fiduciary capacity for beneficiaries such as stablecoin holders. This is a specific trust service; it does not by itself authorize the bank or its parent company to issue any stablecoin it chooses.
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Related reserve management
In the Ripple application, the OCC treated proposed management of liquid reserve assets on a directed basis, in connection with related trust or fiduciary services, as within the proposed bank’s trust company operations or related activities. That decision concerns the proposal before the OCC, not every possible reserve-management arrangement. OCC decision letter
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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 and institutions within its legal analysis; it is not automatic authorization for all crypto activity. Interpretive Letter 1183
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Does the charter let the company take deposits or make loans?
Do not assume so. The OCC’s trust-charter rule and the cited crypto-bank decisions establish authority for trust company operations and related activities, not blanket authority to conduct every business associated with a full-service commercial bank. The examples covered here do not establish that a particular trust bank may take ordinary customer deposits, make loans, or offer every payment or crypto product. A company’s permitted activities must be checked against its specific OCC charter, approval and conditions.
How application and operating status differ
A company’s progress through the charter process matters. In December 2025, the OCC announced conditional approvals for five national trust bank applications, subject to the applicants meeting OCC conditions. Conditional approval is not the same as permission to immediately launch every proposed service. OCC announcement of conditional approvals
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OCC records also distinguish applications at different stages. Coinbase National Trust Company’s OCC record lists approval on April 2, 2026; the OCC’s digital-assets application list separately includes pending filings. An application received, conditional approval, approval and consummated or effective status are not interchangeable. Check the underlying OCC entry and its date before describing a company as approved or operating. Coinbase National Trust Company OCC record · OCC digital-assets application list
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For a meaningful comparison, look beyond a company’s public description and review the OCC record and decision.
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- Identify the proposed service. Is the application for custody, fiduciary trustee work, reserve management, or another activity?
- Check the capacity. Determine whether the bank proposes to act as a fiduciary, in a non-fiduciary capacity, or in both roles.
- Identify the application route. The proposal may be for a new charter or a conversion of an existing state trust company.
- Verify the milestone and date. Distinguish receipt, conditional approval, approval and consummated or effective status using current OCC records.
- Read the conditions and scope. The actual decision and approved business plan control; a company’s general description does not expand its authority.
What the OCC figures do—and do not—show
The OCC reported that, as of September 30, 2025, OCC-supervised uninsured national trust banks had $6.8 trillion in assets under administration: $1.6 trillion in custody and safekeeping accounts and $5.2 trillion in fiduciary accounts. Those figures describe the full covered population, not crypto banks alone. OCC Annual Report 2025
In remarks published August 19, 2026, Comptroller of the Currency Jonathan V. Gould said that 23 of 40 new bank charter applications involved some form of digital-asset activity. That is a figure for the applications in the time frame he described, not a timeless share of all charter applicants or a count of approved crypto banks. OCC remarks by Comptroller Jonathan V. Gould
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