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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, an OCC-approved plan may cover institutional digital-asset custody, fiduciary services such as collateral trustee work, and related reserve management. The charter is not a blanket license for every crypto activity or the same thing as authority to operate a full-service commercial bank.
What a national trust bank charter means
The Office of the Comptroller of the Currency (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 operations to those of a trust company and activities related to them. In a final rule issued in February 2026 and effective April 1, 2026, the OCC clarified that this authority encompasses related non-fiduciary activities as well as fiduciary ones. OCC final rule
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Trust company work is not confined to managing assets as a fiduciary. It can include related non-fiduciary services such as custody and safekeeping. Which services a particular national trust bank may provide depends on its approved business plan, the OCC’s decision, and any conditions attached to that decision.
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OCC decisions illustrate several digital-asset services that may fit within trust company operations or activities related to them. The examples are tied to the applications and arrangements reviewed; they do not approve every product a crypto company might offer.
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Digital-asset custody and safekeeping
A national trust bank may be able to hold digital assets for institutional clients or affiliates under the arrangements described in its approved plan. Whether the bank acts in a fiduciary or non-fiduciary capacity depends on the specific service and its approval. OCC interpretation and action
Fiduciary trustee services
An approved plan may include acting as a collateral trustee for the benefit of stablecoin holders or other beneficiaries. This is a fiduciary service, not a general authorization to issue or market stablecoins.
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Related reserve management
A bank may manage liquid reserve assets on a directed basis when that work is part of a related trust or fiduciary arrangement reviewed by the OCC. The scope depends on the particular proposal and decision; it should not be read as blanket approval for stablecoin issuance or reserve management in any form.
Other activities covered by OCC interpretations
In March 2025, the OCC’s 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. Its conclusions concern the activities and institutions addressed by the letter, not all crypto activity by all firms. OCC Interpretive Letter 1183
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What the charter does not establish
A national trust bank charter is not a general crypto license. The cited OCC decisions support specific trust and related activities, not automatic permission to run an exchange, issue a stablecoin, or conduct every other crypto business line. Nor do the reviewed decisions establish blanket authority for a trust bank to take deposits or make loans as a full-service commercial bank. Evaluate each proposed service against the applicable rule, OCC decision, and approved plan.
How to read an application’s status
OCC applications are reviewed individually. The milestones below are not interchangeable: an application on file does not mean the OCC has approved it, and an approval does not erase conditions or automatically establish that every planned activity can start.
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| Milestone | What it tells you |
|---|---|
| Received or pending | The OCC has an application under consideration; the applicant has not thereby received approval. The agency’s digital-assets list includes pending applications and is updated as filings are received. OCC digital-assets applications |
| Conditional approval | The OCC has conditionally approved an application, subject to requirements the applicant must satisfy. In December 2025, the OCC announced conditional approvals for five national trust bank applications and said the institutions would join the OCC-supervised national trust banks subject to meeting OCC conditions. OCC announcement |
| Approval | An OCC record may list an approval date, but that label alone should not be expanded into a claim that the bank has commenced every proposed activity. For example, the OCC record for Coinbase National Trust Company lists approval on April 2, 2026. OCC national bank records |
| Consummated or effective | Check the OCC record for the institution’s effective status and any conditions before describing it as operating. Do not treat application, conditional approval, approval, and effective status as synonyms. |
How to compare crypto trust bank proposals
For a useful comparison, look beyond a company’s broad description of its plans. Check the OCC record and the approved scope across these dimensions:
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- Capacity: whether the bank will act in a fiduciary or non-fiduciary role.
- Application route: a new national charter or conversion of an existing state trust company.
- Regulatory milestone: received, conditional approval, approval, or consummated/effective.
- Conditions and scope: the actual OCC decision and business plan, rather than a broad public summary.
What the OCC figures say—and do not say
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, according to the OCC. These figures describe the entire stated population, not crypto trust banks alone. OCC trust banks overview
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In remarks published August 19, 2026, Comptroller Jonathan V. Gould said that 23 of 40 new bank charter applications involved some form of digital-asset activity. He also said, “Over half of those bank charters in the business plans for those bank charters involve some form of digital asset activity.” That is his description of the applications in the stated period, not a timeless share of all bank charters or a count of approved crypto banks. OCC remarks, August 19, 2026
Why the OCC’s decision matters
The practical question is not simply whether a company has a national trust bank charter. It is what activities the OCC approved, in what capacity the bank will perform them, what conditions apply, and whether the institution has reached the relevant operating milestone. The OCC’s decisions are specific to the record before it, so a precedent for one custody or reserve arrangement should not be treated as automatic permission for another.
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