Coinbase Secures Full OCC Federal Trust Bank Charter, Takes Over Institutional Custody Business
The U.S. Office of the Comptroller of the Currency (OCC) has formally granted Coinbase National Trust a full national trust bank charter, upgrading the conditional approval the company received in April this year to an operational federal charter. The New York-headquartered trust bank will eventually take over, in its capacity as a fiduciary, the institutional custody business currently handled by Coinbase’s New York State Department of Financial Services (NYDFS)-chartered subsidiary. This makes Coinbase one of the few crypto-native companies to have completed its regulatory transition at the federal level.
The compliance process took nearly a year and a half. Coinbase first applied to the OCC to establish Coinbase National Trust Company on October 3, 2025, and received conditional approval in April this year. After spending several months building out its compliance systems, hiring essential personnel, and undergoing rigorous supervisory reviews, the OCC finally granted its full approval recently.
What can a trust bank do if it doesn’t take deposits or make loans?
Under the OCC’s approval order, the bank’s business scope is clearly defined. It may only conduct trust company and related activities, and does not meet the definition of a traditional “bank” under the Bank Holding Company Act. This means it cannot both accept demand deposits and make commercial loans.
The bank also does not participate in federal deposit insurance. Customers’ fiat currency holdings will be held in third-party banks’ “for the benefit of others” (FBO) accounts and will not become deposit liabilities of the bank itself. Its core operations fall into three main areas:
Core custody: Safely safeguarding crypto assets for institutional clients in its capacity as a fiduciary.
Asset transfers: Allowing custody clients to receive, hold, and transfer the fiat and digital assets held in custody within their own accounts.
Referral bridge: Steering custody clients toward products offered by Coinbase affiliates, such as Staking, Prime Trading, and Prime Financing. (These additional services, however, are not provided directly by the trust bank.)
Moving the custody business into a federal framework within three years
Under the plan approved by the OCC, the custody business currently handled by Coinbase Custody Trust Company, a NYDFS-chartered entity, will be fully transferred to the new federal trust bank during its three-year de novo period.
For institutional clients, the biggest change is regulatory consistency: whereas they previously had to navigate a patchwork of state licenses and complex examinations, they will now operate under a single federal framework with unified capital standards, fiduciary duties, and examination requirements.
Who opposes the charter?
Despite the smooth progress, market criticism and legal challenges have continued. The Independent Community Bankers of America (ICBA) submitted an objection to the OCC, arguing that Coinbase’s business model does not meet the statutory requirements for a national trust bank. It warned that granting a crypto institution without deposit insurance access to the federal banking system would amount to “legitimacy without obligations to the public.” Advocacy group NCRC has also publicly criticized the move, arguing that bank charters should serve the public interest.
After the GENIUS Act, trust charters become standard
A key force driving crypto companies to pursue these charters is the GENIUS Act, recently passed in the United States. The act clears the way for federally chartered institutions to issue payment stablecoins, giving companies that previously focused solely on custody a compliant path to issuing their own coins.
The OCC’s list of approved applicants has gradually come to include a number of leading crypto industry players, including BitGo, Fidelity Digital Asset Services, Paxos, Ripple, Bridge, and Foris DAX, the parent company of Crypto.com. Coinbase, the largest among them, has now finally completed this important piece of its federal trust status.
The U.S. Office of the Comptroller of the Currency (OCC) has formally granted Coinbase National Trust a full national trust bank charter, upgrading the conditional approval the company received in April this year to an operational federal charter. The New York-headquartered trust bank will eventually take over, in its capacity as a fiduciary, the institutional custody business currently handled by Coinbase’s New York State Department of Financial Services (NYDFS)-chartered subsidiary. This makes Coinbase one of the few crypto-native companies to have completed its regulatory transition at the federal level.
The compliance process took nearly a year and a half. Coinbase first applied to the OCC to establish Coinbase National Trust Company on October 3, 2025, and received conditional approval in April this year. After spending several months building out its compliance systems, hiring essential personnel, and undergoing rigorous supervisory reviews, the OCC finally granted its full approval recently.
What can a trust bank do if it doesn’t take deposits or make loans?
Under the OCC’s approval order, the bank’s business scope is clearly defined. It may only conduct trust company and related activities, and does not meet the definition of a traditional “bank” under the Bank Holding Company Act. This means it cannot both accept demand deposits and make commercial loans.
The bank also does not participate in federal deposit insurance. Customers’ fiat currency holdings will be held in third-party banks’ “for the benefit of others” (FBO) accounts and will not become deposit liabilities of the bank itself. Its core operations fall into three main areas:
Core custody: Safely safeguarding crypto assets for institutional clients in its capacity as a fiduciary.
Asset transfers: Allowing custody clients to receive, hold, and transfer the fiat and digital assets held in custody within their own accounts.
Referral bridge: Steering custody clients toward products offered by Coinbase affiliates, such as Staking, Prime Trading, and Prime Financing. (These additional services, however, are not provided directly by the trust bank.)
Moving the custody business into a federal framework within three years
Under the plan approved by the OCC, the custody business currently handled by Coinbase Custody Trust Company, a NYDFS-chartered entity, will be fully transferred to the new federal trust bank during its three-year de novo period.
For institutional clients, the biggest change is regulatory consistency: whereas they previously had to navigate a patchwork of state licenses and complex examinations, they will now operate under a single federal framework with unified capital standards, fiduciary duties, and examination requirements.
Who opposes the charter?
Despite the smooth progress, market criticism and legal challenges have continued. The Independent Community Bankers of America (ICBA) submitted an objection to the OCC, arguing that Coinbase’s business model does not meet the statutory requirements for a national trust bank. It warned that granting a crypto institution without deposit insurance access to the federal banking system would amount to “legitimacy without obligations to the public.” Advocacy group NCRC has also publicly criticized the move, arguing that bank charters should serve the public interest.
After the GENIUS Act, trust charters become standard
A key force driving crypto companies to pursue these charters is the GENIUS Act, recently passed in the United States. The act clears the way for federally chartered institutions to issue payment stablecoins, giving companies that previously focused solely on custody a compliant path to issuing their own coins.
The OCC’s list of approved applicants has gradually come to include a number of leading crypto industry players, including BitGo, Fidelity Digital Asset Services, Paxos, Ripple, Bridge, and Foris DAX, the parent company of Crypto.com. Coinbase, the largest among them, has now finally completed this important piece of its federal trust status.