Crypto companies apply to the Office of the Comptroller of the Currency (OCC), which reviews each proposal for a national trust bank. A conditional approval is only an intermediate step: the applicant must meet its specific conditions, complete the bank-in-organization and pre-opening requirements, and receive final OCC authorization before it can begin business.
What a national trust bank charter allows
A national trust bank is a national bank with a limited trust-company business scope, not automatically a full-service retail or commercial bank. Depending on the activities the OCC approves, its work may include fiduciary services, custody and safekeeping, and activities related to those services. In its decision on Coinbase’s proposal, the OCC described fiduciary digital-asset custody aimed primarily at institutional clients, along with activities related to custody accounts.
| # | Preview | Product | Price | |
|---|---|---|---|---|
| 1 |
|
Banking and Financial Institutions Law in a Nutshell | $65.00 | Buy on Amazon |
| 2 |
|
Principles of Financial Regulation | $52.61 | Buy on Amazon |
| 3 |
|
Banking Law and Regulation | $41.95 | Buy on Amazon |
| 4 |
|
The Law of Banking and Financial Institutions | $32.60 | Buy on Amazon |
| 5 |
|
The Keys to Banking Law: A Handbook for Lawyers | $15.33 | Buy on Amazon |
As an Amazon Associate I earn from qualifying purchases.
The approved scope depends on the individual application, decision letter and business plan. The Coinbase decision, for example, said the proposed institution would not be an insured depository institution and that the Community Reinvestment Act did not apply to that applicant as a matter of law. That finding is specific to the proposal the OCC reviewed; it should not be treated as a universal statement about every trust bank. The decision does not make a trust charter shorthand for ordinary checking or savings accounts, general-purpose deposit-taking, or lending.
How a crypto company applies
- Define a business that fits trust-bank authority. The applicant sets out its proposed activities, customers, governance and operating model in a business plan. The OCC can limit authorization to activities it finds permissible and may tie the bank’s operations to the plan and conditions in its decision.
- Submit an application to the OCC. The OCC’s Digital Assets Licensing Applications page lists applications from entities planning digital-asset products or services and links to Corporate Applications Search (CAS), where case-specific records can be found. The OCC makes public portions of applications available subject to public comment.
- Undergo a charter review. The OCC’s Chartering, Organization and Structure unit assesses applications against statutory standards and supervisory expectations. Relevant considerations identified in the Coinbase decision included management competence, safe and sound operation, profitability, and a robust board-approved Bank Secrecy Act/anti-money-laundering and Office of Foreign Assets Control compliance program, including staff training.
- Respond to the decision and its conditions. The OCC may issue conditional approval. The applicant then has to satisfy the requirements stated in its own decision and complete the bank-in-organization process; conditional approval by itself is not permission to start banking.
- Complete pre-opening steps and obtain final authorization. Before opening, the applicant must meet applicable conditions, establish required governance and policies, obtain other required regulatory approvals, and complete the OCC’s pre-opening process. The OCC’s Ripple National Trust Bank conditional approval letter, for example, requires at least $11.7 million in Tier 1 capital. That is a condition for Ripple’s application, not a universal minimum established for all applicants.
How long the process takes
The OCC says it seeks to decide complete applications within 120 days. This is the agency’s stated target, not a guarantee that an applicant will receive final approval or open within that period. The review clock depends on a complete application, and any conditions, organization work and pre-opening steps add to the time before operations can begin. The applicant’s decision letter sets out its own requirements.
#1 Best Overall
De novo charter versus converting an existing trust company
A de novo application proposes a new national bank. A conversion application seeks to move an existing state-chartered trust company into the national system. The OCC’s December 2025 announcement included both types, but the route alone does not establish what a particular company may do or when it may open.
| Question | De novo national trust bank | Conversion to a national trust bank |
|---|---|---|
| What is proposed? | Creation of a new national bank. | Conversion of an existing state-chartered trust company. |
| What activities may it conduct? | The activities the OCC approves for that applicant, within the authorized trust-company scope. | The activities the OCC approves for that applicant, within the authorized trust-company scope. |
| What determines when it can begin business? | The conditions, organization requirements and final authorization applicable to the new bank. | The conditions and approvals applicable to the conversion and resulting national bank. |
In either route, the business plan and individual decision letter—not the label “national trust bank”—determine the approved scope and conditions.
Rank #2
What recent OCC decisions show
On December 12, 2025, the OCC announced conditional approvals for five digital-asset-related trust bank applications: de novo approvals for 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 records conditional approvals, not that all five institutions had opened. The OCC described its process as “transparent, apolitical and nonpartisan”; that is the agency’s characterization of its own review.
Recommended Free Tools
The OCC’s CAS record says Coinbase’s application was received on October 3, 2025, and approved on April 2, 2026. Its decision discusses the custody-focused proposal and the activities approved for that applicant.
Rank #3
For context, the OCC’s de novo chartering page reports that it received 44 de novo applications, approved 27, denied two and returned one between January 2025 and September 18, 2026. These figures cover all de novo applications, not crypto-only applications. The OCC also says it received fewer than four charter applications per year on average from 2011 through 2024, attributing that low level to its prior regulatory approach.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.How to check an applicant’s status
Application lists and case records can change. To verify whether a crypto company has applied, received conditional approval or reached a later stage, check the OCC’s digital-assets licensing list and open the relevant CAS record. Read the decision itself to distinguish conditional approval from final authorization and to see the activities and conditions that apply to that applicant.
Quick Recap
Sources
- OCC: De Novo Chartering
- OCC: Digital Assets Licensing Applications
- OCC: December 12, 2025 conditional approvals announcement
- OCC: Ripple National Trust Bank conditional approval letter
- OCC: Coinbase National Trust Company decision
- OCC: Coinbase CAS application record
Product prices and availability are accurate as of the date/time indicated and are subject to change. Any price and availability information displayed on Amazon at the time of purchase will apply.
