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If your crypto custodian says its bank is changing or losing its charter, first find out whether the bank is changing status, has actually failed, or whether the crypto company itself is stopping service. Those are different events, and none by itself proves that your crypto has been lost, transferred, or insured. Save your account records, identify which legal entity holds your crypto and any cash, and get written instructions from the custodian before taking action.
First, identify what has actually happened
“Loses its charter” can describe several situations, and a notice about one does not establish the others. A charter conversion, merger, or other change to a bank’s status is not the same as a bank failure. A crypto company may also change banking partners or suspend its own service while the bank remains open. Start with the notice’s exact wording, the named legal entities, and any effective date.
| Event | What it means for your next step |
|---|---|
| A bank charter or structure changes | Confirm which institution will hold cash or provide services after the change, when it takes effect, and whether your custody agreement or access changes. A change alone does not establish that the bank failed or that crypto custody ends. |
| An insured bank fails | Follow official instructions from the FDIC or other named receiver about deposits and claims. The FDIC may arrange for another bank to assume insured deposits or pay insured depositors directly; that process does not by itself determine what happens to crypto held in custody. |
| A nonbank crypto custodian suspends service or becomes insolvent | Use the custodian’s formal notice and any applicable court or receiver process. FDIC deposit insurance does not cover a nonbank company’s failure or its crypto assets. |
The OCC handles filings that establish or change the structure and activities of national banks and federal savings associations. If the institution is federally chartered, check OCC institution and licensing records; for a state-chartered bank, identify the relevant state banking regulator. The OCC’s May 7, 2025 statement says national banks and federal savings associations may buy and sell assets held in custody at a customer’s direction and may outsource bank-permissible crypto custody and execution, subject to third-party risk management and applicable law. That authority does not tell you which entity holds your particular assets or what your contract provides.
What to do now
1. Preserve your records
Before an app, website, or support channel becomes unavailable, download or save:
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- Account statements, crypto and cash balances, transaction history, and tax documents.
- The custody agreement, deposit disclosures, and any terms governing transfers, termination, or disputes.
- The charter-change, bank-change, service-suspension, or withdrawal notice, plus support messages.
- Transaction IDs, wallet addresses, dates, and screenshots that show balances or attempted withdrawals.
Keep copies somewhere you can access if you lose access to the account. This is a practical record-preservation step, not a regulator’s universal checklist.
2. Map the entities and assets
Write down the exact legal name of the customer-facing crypto company, the bank named in the notice or deposit disclosures, any sub-custodian, and any proposed successor. Then separate the balances into crypto and cash. A brand name in an app may not be the legal entity holding either one.
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For crypto, check the agreement and account disclosures for who is identified as custodian, whether a sub-custodian is used, who controls the private keys, and how customer ownership and segregation are described. The OCC described crypto custody in its July 22, 2020 announcement as including safekeeping the unique cryptographic keys associated with cryptocurrency. That description helps explain the service; it does not establish who owns or controls the keys in your particular arrangement.
3. Request a written, account-specific explanation
Use the custodian’s authenticated support channel and ask for written answers to these questions:
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- Is the announced change proposed or complete, and what is its effective date?
- Will custody continue? Which legal entity will hold or control the crypto after the change?
- Where is any cash held, in whose name, and in what kind of account?
- Are crypto assets segregated, or held through a sub-custodian? What records identify your interest?
- Can you withdraw or transfer crypto and cash now? Are there deadlines, fees, limits, or restrictions?
- If access is interrupted, how and where do you submit a claim?
Do not give support staff your password, seed phrase, or private keys. Independently verify any destination address before authorizing a transfer; do not rely on an address supplied in an unexpected message.
Are your crypto and cash insured?
Treat crypto and cash as separate questions. The FDIC states: “FDIC deposit insurance does not apply to financial products such as stocks, bonds, money market mutual funds, other types of securities, commodities, or crypto assets.” A bank’s involvement in custody does not turn crypto into an insured deposit.
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Cash may be eligible for FDIC deposit insurance if it is actually held in a qualifying deposit account at an insured bank and the applicable ownership, recordkeeping, and coverage requirements are met. If a crypto company claims that cash has pass-through coverage through a partner bank, ask it to identify the bank and account arrangement and explain what records establish each customer’s ownership interest. A company’s claim alone does not prove eligibility.
For fiduciary deposits, the FDIC says it may insure the actual owners when requirements are met, but pays the fiduciary rather than paying its customers directly. The FDIC also says it is not responsible if a fiduciary or custodian fails to establish a deposit account, maintain supporting documentation, or ensure funds are within insured limits. Do not treat a statement that cash is “FDIC insured” as a guarantee that your particular balance qualifies.
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If the bank has actually failed
Use official notices from the FDIC, receiver, or other authority named in the proceeding, and follow their deadlines and claim instructions. The FDIC explains that it may arrange a purchase-and-assumption transaction with a healthy bank or pay insured depositors directly, while acting as receiver for the failed bank’s assets and liabilities. This bank-deposit process does not determine the treatment of crypto held under a custody arrangement.
Keep the bank’s deposit process separate from any claim involving the crypto custodian. If the custodian or another entity is also insolvent, use the receiver or court process identified in that entity’s official notices; do not assume that a bank’s resolution automatically resolves the custodian’s obligations.
How to escalate a dispute or access problem
Send a dated written complaint to the entity responsible for the issue, and retain proof of delivery and any response. Depending on the facts, that may be the crypto custodian, the bank, or both. For a federally chartered bank, the OCC is the relevant federal banking regulator; for a state-chartered institution, identify the state banking regulator. If a receiver or court process has begun, use its designated claim procedure rather than relying only on ordinary customer support.
Consider getting qualified legal advice promptly if substantial assets are inaccessible, a claim deadline is approaching, or the agreement’s ownership, governing-law, or insolvency terms are unclear. Whether a customer has a segregated-asset, trust, bailment, or creditor claim cannot be determined from a general notice: it depends on the agreement, custody records, governing law, applicable regulatory regime, and facts of any receivership or bankruptcy.
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The OCC, Federal Reserve, and FDIC said on July 14, 2025 that crypto safekeeping must be conducted safely and soundly and in compliance with applicable law; their statement said it created no new supervisory expectations. These regulatory statements provide context for banks’ activities, but they do not resolve an individual customer’s access, ownership, or recovery rights. Check the actual notice, account structure, contract, and any official proceeding instructions for those answers.
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