Coinbase gets final OCC approval for its national trust bank, which will hold crypto for clients but take no deposits

Coinbase’s custody business now has its OCC trust charter. Coinbase National Trust Company, a New York-based subsidiary of Coinbase Global, has received final approval from the Office of the Comptroller of the Currency (OCC) to operate as a national trust bank. Coinbase announced it on Monday 9 November. crypto.news, citing OCC licensing records, dates the completion of the charter to Friday 6 November, and American Banker also reports that the OCC acted on Friday. The charter covers custody of crypto and cash for clients, mostly institutions. It does not let the bank take deposits, make loans or, under the plan the OCC approved, issue stablecoins.

The OCC had not posted the final decision itself by Monday midday. Its index of interpretations and corporate decisions, as of about 11:55 UTC on 9 November, lists only the April preliminary approval for Coinbase, and no entry of any kind dated October or November 2026. Until that letter appears, the date rests on the licensing records as reported, and nobody outside the OCC and Coinbase can say whether the final approval changed any of the April conditions.

What is public is the April document, and it is detailed. Corporate Decision #1370, dated 2 April 2026 and signed by Senior Deputy Comptroller Stephen A. Lybarger, sets out what the bank may do, what it may not do and how much money Coinbase must keep inside it. The Coinbase OCC trust charter comes less than two weeks after Ripple received its final OCC approval on 26 October.

Coinbase OCC trust charter: what the bank is allowed to do

The OCC letter describes a narrow business. The bank will provide digital asset custody “as a fiduciary, primarily for institutional clients”, which means it holds assets for others under legal duties of care and loyalty, the same footing as the trust department of a traditional bank.

Around that core, it may offer what the OCC calls transactional services, but only to custody customers and only on assets already in custody. In practice, a client can accept, hold and transfer cash and crypto inside its custody account. The cash side does not sit on the bank’s own balance sheet as deposits: under the OCC letter, fiat held in custody goes into “for benefit of” accounts at third-party banks.

Three Coinbase products appear in the decision: Staking, Prime Trading and Prime Financing. None of them moves into the bank. They stay with Coinbase affiliates, and the bank only connects its custody clients to them under its authority to act as a finder, a long-standing national bank power. The OCC wrote that the bank “will not be providing” those underlying services itself.

The custody business that exists today runs through Coinbase Custody Trust Company, a limited-purpose trust company chartered by the New York State Department of Financial Services (NYDFS). Coinbase told the OCC it will move all of that business to the new national bank over the three-year de novo period. Until then, two trust companies, one state and one federal, will run side by side.

What the charter does not allow

The bank cannot take retail deposits or make loans. When the conditional approval came in April, Greg Tusar, co-CEO of Coinbase Institutional, said Coinbase would not become a commercial bank, accept retail deposits or practise fractional reserve banking, according to Ledger Insights. Condition 1 of the OCC decision writes the limit into the approval: the bank must stick to the operations of a trust company and must not meet the Bank Holding Company Act’s definition of a bank, which covers firms that both take demand deposits and make commercial loans.

It is also uninsured. The bank will not be an FDIC-insured depository institution, and American Banker noted that assets held at these trusts are not covered by federal deposit insurance. One consequence the OCC spelled out: the Community Reinvestment Act, which obliges insured banks to lend in their local communities, does not apply.

A charter is not a Federal Reserve account either. The OCC granted its approval on the understanding that the bank will buy stock in a Federal Reserve Bank, which is membership of the Federal Reserve System. Access to the Fed’s payment rails through a master account is another matter: crypto.news reports that it needs a separate application under the Fed’s account access guidelines. Coinbase has not said whether it has filed one.

Stablecoins: the OCC letter and Coinbase’s later plans do not say the same thing

In the April decision, the OCC answered a public comment about stablecoin issuance in one sentence: “the Bank does not propose to issue stablecoins”, so the issue was “irrelevant” to the application. crypto.news, reporting the final approval, also says the business plan excludes direct issuance.

American Banker describes a longer road. In its account, custody is Coinbase’s immediate focus, and the company later plans to move into stablecoin issuance and servicing, white-label stablecoins for other companies and payments. Those plans are not in the OCC document, and Coinbase has not said whether it will seek a separate role as a stablecoin issuer under the GENIUS Act.

The two accounts can both be true at different times, but the gap matters. Under Condition 3, the bank must give the OCC’s Novel Bank Supervision office 60 days’ written notice and obtain a written non-objection before any significant change to its business plan, during the organisation period and its first three years. Adding stablecoin issuance would, on our reading, be such a change. Condition 2 already requires the bank to conform to the GENIUS Act and the rules that implement it as they take effect, including the OCC final GENIUS rule for stablecoin issuers published on 21 October, which takes effect on 18 January 2027.

For USDC holders, nothing in the decision touches the stablecoin’s reserves: the OCC letter does not give the Coinbase bank any role in holding them. Our comparison of USDT and USDC explains who issues USDC and where its backing sits.

A $60 million capital floor and six months of running costs

The money conditions in the April decision are the clearest measure of how the OCC sees the risk of a crypto trust bank. They apply for the bank’s first three years of operation, and the decision makes them enforceable under 12 USC 1818, the statute behind OCC enforcement actions.

“Eligible liquid assets” is a strict definition. It counts only unencumbered cash, deposits at insured banks maturing within 90 days and US government obligations maturing within 90 days, and only to the extent they exceed the bank’s own liabilities. Obligations of any Coinbase affiliate are excluded, so the parent cannot fill the cushion with its own paper. The 180-day reserve must cover the fixed and variable costs of an orderly wind-down, and it cannot be the same money as the capital buffer.

Coinbase has not said how much capital it has actually put into the bank, when the bank opens to clients or which clients move first. The OCC also cleared seven people to run it, with Rick Schonberg as director and chief executive officer and Alesia Haas, Coinbase’s chief financial officer, as director and CFO. Greg Tusar and chief legal officer Paul Grewal sit on the board with three independent directors.

How the charter fits the OCC’s run of crypto approvals

The Coinbase application dates from October 2025. The preliminary conditional approval followed on 2 April 2026, and final approval about seven months later. Coinbase was not part of the first group: on 12 December 2025, the OCC conditionally approved five other applications, from Circle, Ripple, BitGo, Fidelity Digital Assets and Paxos, according to Banking Dive. BitGo, Fidelity Digital Assets and Paxos were converting existing state trust charters.

Since then the list has grown. American Banker counts nearly two dozen new national trust bank charters approved or conditionally approved during the second Trump administration, more than a dozen of them for crypto firms. The OCC’s own index shows conditional approvals through September, and companies outside crypto are queuing too, such as the corporate card firm Ramp, which applied for a trust charter in October.

The comments the OCC rejected in April show what the opponents argue. Four of the five said the planned activities do not match OCC precedent on fiduciary work; others raised the OCC’s ability to wind down a failed uninsured bank, the bank’s reliance on Coinbase’s shared systems and past enforcement actions against Coinbase affiliates. The OCC answered that it has a supervisory unit for novel banks and a receivership rule for uninsured national banks, and that the link between past enforcement actions and the bank’s planned activities was attenuated and better handled through supervision.

For scale, the OCC’s letter gives a figure for the whole sector: at 31 December 2025, the uninsured national trust banks it supervises reported $7.0 trillion in assets under administration, of which $1.7 trillion was custody and safekeeping and $5.3 trillion fiduciary accounts.

The community bank lawsuit still hangs over trust charters

The final approval lands while the legal basis for these charters is being challenged in court. On 2 October 2026, the Independent Community Bankers of America (ICBA) sued the OCC and Comptroller Jonathan Gould in the US District Court for the District of Columbia, crypto.news reports. The suit targets the OCC’s March 2026 chartering rule, which took effect on 1 April, its Interpretive Letter 1176 and the conditional approval granted to Protego Holdings. We covered the suit when the OCC invited community banks to issue stablecoins.

ICBA president and CEO Rebeca Romero Rainey has argued that digital assets held under a national trust charter lack safeguards that apply at insured banks, according to crypto.news. The Coinbase charter is not named in the suit, but a ruling against the OCC’s reading of the law would reach every trust bank chartered on it.

American Banker writes that litigation and appeals could take years, and that a court would then have to decide what happens to institutions already chartered under the disputed interpretation, from tighter limits to a reversal of the OCC’s reading.

What Coinbase said, and what changes for clients

“We’ve spent years asking for clear rules and rigorous oversight,” Coinbase vice chairman Ryan VanGrack said, according to crypto.news. American Banker attributes the same idea to Rick Schonberg, who heads prime trading and custody and is the trust bank’s chief executive, and quotes him saying the approval “allows us to expand our custody capabilities within a consistent federal regulatory framework”.

For institutions that already keep assets with Coinbase Custody, the change is about the supervisor and the legal wrapper, not the product. Over three years, their custodian moves from New York state oversight to federal oversight by the OCC, with fiduciary duties written into federal law. For a pension fund or an asset manager whose rules require a bank custodian, that difference can decide whether it may use Coinbase at all. This is our analysis; Coinbase has not published a client timeline.

Retail users of the Coinbase app see no change. Their accounts are not moved to the trust bank, and the bank takes no retail deposits. In Europe, Coinbase serves customers under its MiCA licence from Luxembourg’s CSSF, announced in June 2025; the OCC charter is a US authorisation and, on what has been published, changes nothing for EU accounts. Our Coinbase review lists the entities and licences behind each service.

What to watch next

• Publication of the final decision on the OCC website, which would show whether any April condition changed.
• Coinbase’s opening date for the bank and the first custody clients moved from the New York trust company.
• Any notice to the OCC about stablecoin issuance, which Condition 3 would require before such a change.
• A Federal Reserve master account application, which the charter does not grant by itself.
• The next steps in the ICBA case in the District of Columbia.