Crypto Bank Charters and Fed Access

A crypto firm that says it has "a bank charter" may hold any of three permissions. A charter decides what it may do with customer assets. A Federal Reserve account decides whether it can settle payments without a correspondent bank. Issuer status under the GENIUS Act, once the Act applies, decides whether it may issue a dollar stablecoin. Each is decided separately. This post sets out who holds what as of 29 September 2026 and where the public record stops. It describes public documents and is not legal, tax or investment advice.

Three permissions, three decisions

The charter. For a national bank, the Office of the Comptroller of the Currency (OCC); for a state charter, the state banking regulator.
Federal Reserve access. An individual Reserve Bank, at its discretion, under account access guidelines the Board of Governors issued in 2022.
Issuer status. The regulator the GENIUS Act names for each kind of issuer. For an uninsured national bank, that is again the OCC.

What a national trust bank charter allows

In 1978 Congress confirmed, in what is now 12 USC 27(a), the OCC's authority to charter a national bank limited to the operations of a trust company. In the OCC's words in its Coinbase decision, those operations "typically include performing fiduciary activities, as well as other activities that may be non-fiduciary in nature, such as non-fiduciary custody and safekeeping".

The category is not small. Several OCC letters issued between July and September 2026 report that the uninsured national trust banks the OCC supervises, crypto and otherwise, held $7.2 trillion in assets under administration at 31 March 2026: $1.7 trillion in custody and safekeeping accounts and $5.5 trillion in fiduciary accounts. Its Catena letter of 18 September gives $7.7 trillion for the same date.

What the charter withholds matters as much. Each recent approval requires the bank to stay within trust-company activities and not to meet the Bank Holding Company Act definition of a "bank", which, as the OCC notes, excludes uninsured banks that do not both accept demand deposits and make commercial loans. The bank is not an insured depository institution, as the OCC said when rejecting arguments that Community Reinvestment Act duties should apply. Staying outside that definition also keeps a crypto parent out of Federal Reserve holding-company regulation, a point that returns below.

The OCC amended 12 CFR 5.20, effective 1 April 2026, to align it more closely with the statute. Its 2025 interpretive letters widened what banks may do. Letter 1183 (7 March 2025) rescinded the requirement to obtain supervisory non-objection before crypto-asset custody, certain stablecoin activities and node participation. Letter 1184 (7 May 2025) confirmed banks may buy and sell custodied assets at the customer's direction and outsource custody and execution. Letter 1186 (18 November 2025) allowed banks to pay network fees and hold crypto-assets as principal for that purpose. None creates a charter.

The applications, company by company

The route is not new: the OCC conditionally approved Anchorage Trust Company's conversion to a national trust bank on 13 January 2021, a decision it still cites. There are two kinds of decision. A new (de novo) bank receives preliminary conditional approval: final approval "will not be granted until all preopening requirements are met", and until then the OCC may modify, suspend or rescind it. A converting state trust company receives conditional approval, which lapses if the conversion is not completed within six months. Every de novo decision below is preliminary unless marked final.

12 December 2025. The OCC's news release 2025-125 announced five conditional approvals: two de novo banks, First National Digital Currency Bank (Circle's application) and Ripple National Trust Bank, and three conversions from state trust companies, BitGo Bank & Trust, N.A.; Fidelity Digital Assets, N.A.; and Paxos Trust Company, N.A. The OCC's Corporate Applications Search records all three conversions as consummated on 12 December 2025, and BitGo's January 2026 prospectus says its conversion was completed that day.
12 February 2026. Bridge National Trust Bank, New York, owned through Bridge Ventures by Stripe. It plans to issue dollar stablecoins, including as primary issuer of Bridge's white-label xUSD tokens. Minimum tier 1 capital: $45 million.
13 February 2026. National Digital Trust Company, Seattle, owned by Protego Holdings: custody, trading, lending and borrowing, and issuer services. $15 million.
20 February 2026. Foris DAX National Trust Bank, Chicago, to trade as Crypto.com National Trust Bank. The OCC noted it has not proposed stablecoin activities. $15 million.
2 April 2026. Coinbase National Trust Company, New York: fiduciary custody, migrated from Coinbase's New York-chartered trust company over the three-year de novo period, with custody customers given access to affiliates' staking, prime trading and prime financing under the bank's finder authority. No stablecoin issuance. $60 million.
29 May 2026. Laser Digital National Trust Bank, New York, part of Nomura's digital asset business: fiduciary custody of digital assets, securities and fiat currency, plus staking and customer-directed spot trading. $6.5 million.
18 June 2026. Morgan Stanley Digital Trust, N.A., Purchase, New York: digital asset custody, trading and staking in support of Morgan Stanley Wealth Management. $50 million.
2 July 2026. Connectia Trust, N.A., New York, owned by Sony Bank: dollar stablecoin issuance and custody within a closed-loop network limited to Sony group platforms. $60 million.
10 July 2026, final. Circle's own release says the OCC gave final approval to First National Digital Currency Bank, N.A., operating as Circle National Trust, which will offer fiduciary digital asset custody to Circle and its affiliates at opening, with USDC reserve management a future capability. The OCC's Corporate Applications Search records the charter as consummated on 24 July 2026.
14 August 2026. World Liberty Trust Company, N.A., Bay Harbor Islands, Florida. It would issue the USD1 stablecoin in a non-fiduciary capacity, taking over from BitGo Bank & Trust, which the OCC describes as USD1's current exclusive issuer and custodian. The OCC records that, to date, it does not plan to seek a Federal Reserve master account. $20 million.
18 September 2026. Three decisions. Catena Trust Bank, N.A., New York, owned by Catena Labs: custody, investment management, trust, conversion and clearing, and execution services, including for payment stablecoins that will comply with the GENIUS Act "once effective" ($10 million). Agora National Trust Bank, New York, which would take over issuance of the AUSD stablecoin from a Bermuda affiliate ($10 million). And the conversion of Bastion Platforms Trust Company, a New York trust company, for white-label stablecoin issuance and custody ($6 million).

Across these 2026 decisions, capital minima run from $6 million to $60 million, set per business plan, and each requires 60 days' notice and OCC non-objection before a significant departure from the business plan in the bank's first three years. Each also expects the bank to apply for Federal Reserve Bank stock under 12 USC 222. That is membership, not an account.

As at 29 September 2026, the OCC's applications database, which runs about five days behind, showed no consummation for Ripple National Trust Bank or for any of the 2026 approvals above.

State charters: Wyoming and New York

Wyoming's Division of Banking describes a special purpose depository institution (SPDI) as one that may "receive deposits and conduct other activity incidental to the business of banking, including custody, asset servicing, fiduciary asset management, and related activities". Customer fiat deposits must always be backed 100% or more by unencumbered liquid assets and may not be lent, and FDIC insurance is optional. The undated page says four SPDI charters have been approved.

New York's Department of Financial Services (NYDFS) says a limited-purpose trust company "can exercise fiduciary powers, while a BitLicensee cannot", and can transmit money in New York without a separate licence. Circle announced on 31 July 2026 that NYDFS had granted a limited-purpose trust charter to Circle Internet Trust Company LLC, doing business as Circle New York Trust; the release does not list its permissions. The OCC's Bridge decision records that Bridge Ventures has also applied to NYDFS for one.

State and national routes are stages as much as rivals: BitGo, Fidelity Digital Assets and Paxos have converted, Bastion has approval to, and Coinbase would move custody from its New York trust company. The Coinbase decision explains why: 12 USC 92a lets a national bank act in any fiduciary capacity that competing state trust companies may use under its state's law, and, the OCC noted, New York law lets state trust companies provide cryptocurrency custody as fiduciaries. The national charter borrows the state's permission and adds nationwide reach.

Federal Reserve access: tiers, courts and one limited account

As the Board's staff memo of 7 May 2026 summarises the 2022 guidelines, Tier 1 is federally insured; Tier 2 is uninsured, under federal prudential supervision, with a holding company subject to Federal Reserve oversight "by statute or commitment"; Tier 3 is every other uninsured institution. Tier 2 and Tier 3 requests typically face "greater due diligence and scrutiny". On those definitions, a national trust bank whose parent stays outside holding-company regulation, and has not committed to Federal Reserve oversight, would appear to fall in Tier 3. That is a reading, not a Federal Reserve statement.

The courts have not helped applicants. In Custodia Bank's case, the Tenth Circuit held on 31 October 2025, by 2–1, that Reserve Banks may reject master account requests from legally eligible entities; the full court denied rehearing en banc on 13 March 2026, by 7–3, with the dissent arguing that the Fed had claimed unreviewable discretion. Custodia petitioned the Supreme Court on 10 July 2026 (No. 26-62). The docket shows the respondents' time to reply extended to 13 October 2026, so the Court has not yet decided whether to hear the case.

Then came Kraken. On 4 March 2026 the Federal Reserve Bank of Kansas City approved a "limited purpose account" for Kraken Financial, a Wyoming SPDI, for an initial one-year term, classed as Tier 3, with restrictions tailored to its business model and risk profile. The Reserve Bank does not disclose which services Kraken can use. Trade press called it a master account; the Reserve Bank did not. The distinction matters: a master account, in the Board staff's words, "does not have any standard usage restrictions".

The payment account proposal

On 20 May 2026 the Board requested comment on a "payment account", a constrained alternative to a master account for clearing and settling the holder's own payments. Comments closed on 27 July 2026. The terms below come from the staff memo of 7 May 2026 that recommended the notices, not the Board's final text.

A closing balance limit set by the Reserve Bank from expected payment activity, not above $1 billion, and no limit on intraday balances. The December 2025 prototype, published as a request for information, had proposed the lesser of $500 million or 10% of total assets.
No discount window credit, no intraday credit and no interest on balances.
Only services where overdrafts can be rejected automatically: Fedwire Funds, FedNow, the National Settlement Service, and Fedwire Securities transfers free of payment. No FedACH: staff saw "no reasonable way" to allow it while mitigating credit risk to the Reserve Banks.
No acting as a correspondent for other institutions, and a duty to mitigate illicit finance risks.
Review generally within 90 calendar days of a complete file, with Reserve Bank discretion retained.

The Board also encouraged Reserve Banks to pause decisions on Tier 3 requests until it completes the work; staff recommended that the pause be expected to end on or before 31 December 2026. The Board said the proposal "would not expand or otherwise change legal eligibility" for Federal Reserve accounts.

A 19 May 2026 executive order, as reported by Mayer Brown and PYMNTS, gave the Fed 120 days to report on what access current law allows. PYMNTS reported on 17 September that the deadline had passed on 16 September, that about 100 comments had been received and that no final decision had been issued; the Board's press releases to 29 September 2026 show none. PYMNTS also reported that Governor Christopher Waller wrote, in a 31 August letter to the White House, that the Federal Reserve "does not have the authority to expand legal eligibility", which would require Congress.

Where the GENIUS Act meets the charter

The Act, Public Law 119-27, was signed on 18 July 2025 and takes effect on the earlier of 18 January 2027 and 120 days after final implementing regulations. It is adopted but not yet applying. Three links to charters matter.

First, in the World Liberty decision the OCC says the Act's definition of a federal qualified payment stablecoin issuer includes an uninsured national bank, and that payment stablecoins are not deposits and carry no FDIC insurance.

Second, approvals are hedged against it. The Protego, Connectia, World Liberty, Catena, Agora and Bastion letters require the bank, where necessary, to "conform, cease, or divest" activities to comply with the Act and its regulations, as the OCC determines in its sole discretion. The Coinbase letter requires it to conform.

Third, the OCC's implementing rule is still a proposal, issued on 25 February 2026 with comments closing on 1 May. The statute set 18 July 2026 for regulations; as at 29 September 2026, no final OCC rule had been published in the Federal Register.

A charter is therefore a route to issuing, not an issuer licence. A firm can hold one and issue nothing, as Coinbase and Crypto.com propose.

What is still open

When Ripple and the 2026 de novo banks receive final approval, and on what conditions.
The final payment account terms, and when the Tier 3 pause ends.
Who is legally eligible for any Federal Reserve account; the Fed's reported position is that only Congress can widen it.
Whether the OCC's final GENIUS rule keeps the proposal's shape.
Whether the Supreme Court takes Custodia's case.
Whether bank trade groups press their objections. Two argued in the Coinbase file that its activities did not fit OCC precedent on fiduciary activities; the OCC rejected the argument.

For the demand side, see how corporate treasuries use stablecoin payments.