A national trust bank charter can let a crypto company operate a federally chartered bank limited to trust-company operations and related activities. That scope can include digital-asset custody and, depending on the institution’s approved business plan and conditions, certain services connected to custody, such as customer-directed execution or staking. It is not a general license for every crypto product or the same thing as authority to operate a full-service commercial bank.
The key is to distinguish what the Office of the Comptroller of the Currency (OCC) recognizes as potentially permissible from what it has approved for a particular institution. An application, and even a preliminary conditional approval, is not final authority to open.
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What the charter is—and where its limits come from
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.” In Interpretive Letter 1176, the OCC explained that trust-company operations can include both fiduciary work and non-fiduciary activities such as custody and safekeeping. A national trust bank is therefore not limited to acting as a fiduciary under 12 C.F.R. Part 9.
The OCC’s final rule issued February 27, 2026, and effective April 1, 2026, amended 12 C.F.R. § 5.20 to describe the scope in terms of trust-company operations and related activities, rather than only fiduciary activities. The OCC said the rule “would neither expand nor contract the OCC’s authority to charter a national bank.” The rule clarifies the framework; it does not turn a limited-purpose charter into a blanket approval for any financial or crypto business.
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Where an activity is fiduciary, the applicable fiduciary requirements remain relevant, including 12 U.S.C. § 92a and Part 9. Interpretive Letter 1176 did not waive those duties or change what it means to act in a fiduciary capacity. A 2021 OCC letter, Interpretive Letter 1179, made that distinction historically; its non-objection process was later rescinded in March 2025.
Which crypto activities may fit
OCC materials recognize several activities that can fit within trust-company operations or be related to them. Whether a specific bank may offer one depends on its charter, approved business plan, conditions, and applicable law—not just on the words “national trust bank.”
| Activity | How it may fit | What the example does not establish |
|---|---|---|
| Digital-asset custody and safekeeping | The OCC has treated custody and safekeeping as trust-company operations, including custody of crypto-assets. Depending on the customer relationship, custody may be fiduciary or non-fiduciary. | The word “custody” alone does not establish whether a service is fiduciary, or whether a particular institution has OCC approval to provide it. |
| Execution, trading, and settlement connected to custody | OCC materials describe customer-directed buying and selling of assets held in custody, along with related settlement functions, as potentially permissible in connection with custody accounts. The OCC’s 2025 statement also addresses outsourcing bank-permissible custody and execution activity, subject to appropriate third-party risk management and safe, sound operations. | This is not general approval for a standalone trading venue or every trading service. The connection to the approved custody activity and the institution’s controls matter. |
| Staking and other ancillary custody services | A 2026 OCC decision discussing Fidelity Digital Assets’ conversion cites prior approvals that allowed staking as an ancillary custody service. It also discusses certain trading-related services tied to customers’ custody accounts. | The decision illustrates treatment of specific proposed services; it is not an unqualified endorsement of every staking model or a universal permission for all chartered trust banks. |
| Collateral-trustee and reserve-related functions | In its December 12, 2025 preliminary conditional approval for Ripple National Trust Bank, the OCC described proposed fiduciary crypto custody, collateral-trustee work, and directed management of liquid assets backing an affiliate’s stablecoin. | Those activities were part of Ripple’s proposal and conditional approval. They do not establish that another applicant will receive the same scope or that a trust-bank charter alone permits all stablecoin issuance or reserve services. |
The OCC’s March 2025 interpretive index also reaffirmed that national banks may provide crypto custody, hold deposits that back stablecoins, and use distributed-ledger technology and stablecoins for otherwise permissible payment activities. Those statements concern activities permissible to national banks generally; they should not be confused with the narrower scope of a bank limited to trust-company operations.
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What the charter does not automatically authorize
Every crypto business or financial product
A trust-company-limited bank must stay within trust-company operations and activities related to them. The charter does not automatically authorize an exchange, lending business, payments product, token issuance program, or any other particular service. Each activity needs to fit the bank’s legal authority and the institution’s approved scope.
Full-service commercial banking
A national trust bank charter is not simply a general-purpose commercial bank charter. At the same time, the available OCC materials do not support a universal claim that every trust bank categorically can or cannot take deposits, lend, or offer a particular retail service. For an individual institution, check its charter, approved business plan, conditions, and applicable rules rather than inferring its powers from the label alone.
Automatic approval to begin operating
An application is not an approval. Preliminary conditional approval is not final authority to commence business either. In Ripple’s December 12, 2025 decision, the OCC made final authorization contingent on satisfying pre-opening requirements and reserved the ability to modify, suspend, or rescind the preliminary approval. The OCC lists pending applications separately from final charter decisions.
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Exemption from safety, soundness, and other legal requirements
An OCC determination that an activity may be permissible does not establish that a company’s particular controls, customer terms, or implementation are risk-free. The OCC’s discussion of outsourced custody and execution activity makes clear that third-party risk management and safe and sound operations remain relevant. Other applicable legal requirements continue to apply as well.
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How to assess a crypto company’s charter status and scope
When comparing companies, focus on the institution and the precise activity—not just whether a company says it has a “trust bank charter.”
- Check the status. Distinguish a pending application, a preliminary conditional approval, and final authorization. The OCC’s applications listing and the institution’s decision documents identify these different stages.
- Read the approved activities. Look for the services named in the OCC decision and approved business plan. Do not assume that an approval for custody automatically covers unrelated products.
- Identify the legal capacity. Determine whether the described custody or other service is fiduciary or non-fiduciary. Fiduciary activities remain subject to the applicable requirements, including Part 9.
- Test the relationship to trust operations. For a non-fiduciary service, ask how it is connected to the bank’s trust-company operations—for example, whether execution is customer-directed and tied to assets in a custody account.
- Read the conditions and operating arrangements. Check pre-opening requirements, risk controls, third-party arrangements, and any limits stated in the decision.
What current OCC examples show
Ripple National Trust Bank
The OCC granted Ripple National Trust Bank preliminary conditional approval on December 12, 2025. Its decision described proposed fiduciary crypto custody, collateral-trustee services, and directed management of liquid assets backing an affiliate-issued stablecoin. The decision made clear that final approval and authority to commence business depended on meeting pre-opening requirements. This is an example of a specific conditional proposal, not a guarantee that another company can obtain identical powers.
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Fidelity Digital Assets
A 2026 OCC decision concerning Fidelity Digital Assets’ conversion discusses custody and associated services, including staking and trading-related account services. It shows that the OCC may consider such services in relation to a particular institution’s proposed trust operations; it does not create identical permissions for every national trust bank.
Industry scale is not crypto-specific
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. These are aggregate figures for the supervised trust-bank sector, not crypto-asset totals or assets held by any one crypto company.
Bottom line for readers
The charter can provide a federal home for a limited-purpose bank whose trust-company operations may include digital-asset custody and certain related services. The practical answer for any crypto company is narrower: identify its exact OCC status, read which activities are approved and under what conditions, and distinguish that institution-specific authority from the broader categories of activity the OCC says may be permissible.
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