OCC National Trust Bank Route · Bridge's Preliminary Conditional Approval
ConfidenceCertainUpdated2026-08-14Review by2026-11-12Sources4Machine-translatedOriginal (JA)
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This entry sits under fintech index. Read it with Japanese Financial Regulation — Legal System for Tokens, Cryptocurrency, and Payments for adjacent context and Japanese Stablecoin Legal System Three-Layer Structure (JPYC, USDC, Project Pax) for the broader system boundary.
[!info] TL;DR On 2026-02-12, OCC Corporate Decision 1365 granted preliminary conditional approval to the proposed Bridge National Trust Bank. This is not a final charter or operating permit. The OCC explicitly states that it will not grant final approval until pre-opening requirements are met, and Bridge cannot commence banking business until that point. The decision records the proposed activities—stablecoin issuance, custody, orchestration, reserve management, and collateral-trustee services—along with detailed conditions, but does not establish that MTLs in all 50 states become uniformly unnecessary, that Bridge has direct Federal Reserve master-account / Fedwire / FedNow connectivity, or that any valuation premium is warranted. ↗
Bridge Decision’s Verifiable Status
| Item | Content Recorded in OCC Decision | Evidence Boundary |
|---|---|---|
| Approval Stage | Preliminary conditional approval | Not final approval or operating authorization |
| Proposed Owner | Wholly owned subsidiary of Bridge Ventures LLC. Bridge Ventures is a wholly owned subsidiary of Stripe. | Parent company relationships do not eliminate approval conditions or individual entity obligations |
| Proposed Activities | USD stablecoin issuance, digital-asset custody, orchestration, reserve management, collateral trustee | This is a proposed plan and does not mean the bank is currently providing all of these services |
| Charter Scope | Trust-company operations and activities related thereto | Not identical to a full-service insured depository bank |
| GENIUS Act | Activities must conform, cease, or be divested as necessary to comply with the Act and implementing rules | Conditional approval is not a blanket exemption from later rules |
| Opening Gate | Pre-opening examination and final OCC approval required | OCC can modify, suspend, or rescind before final approval |
Source note: all rows come from OCC Corporate Decision 1365, especially pages 1-2, 8-13.
Material conditions
- Minimum USD 45 million tier 1 capital.
- The greater of at least 50% of tier 1 capital or USD 27.5 million must be held in Eligible Liquid Assets.
- A separate 180 days of operating expenses must be maintained in Eligible Liquid Assets.
- Significant business-plan changes require advance notice and an OCC written non-objection.
- The bank must not meet the Bank Holding Company Act section 2(c)(1)-(2) definition of “bank”.
- If capital is not raised within 12 months or the bank does not open within 18 months, the preliminary approval expires absent exceptional relief.
These are the Bridge-specific public conditions in the decision. They replace the prior unsourced route estimates of USD 5-20 million capital, generic 12-24 month timing, and state-by-state cost savings.
State MTL pre-emption: fact-specific, not blanket
OCC Interpretive Letter 1167 concluded that a national bank performing the described federally authorized fiduciary activities did not need state money-transmitter licenses for those activities. The letter expressly says that different facts, laws, or regulations could produce a different result. Bridge’s decision includes fiduciary and non-fiduciary proposed activities. Therefore, the letter supports a legal route for specified fiduciary powers; it does not establish that every stablecoin, orchestration, affiliate, or non-bank activity is exempt from every state requirement. ↗
Federal Reserve and payment-system boundary
The OCC decision says Bridge National Trust Bank will apply for Federal Reserve Bank stock under 12 USC 222. It does not state that Bridge has a Federal Reserve master account or direct Fedwire / FedNow access. Federal Reserve materials describe Fedwire participation through an account relationship and applicable agreements; eligibility and access should be verified from Federal Reserve records rather than inferred from the OCC charter stage. ↗
Verified timeline
| Date | Public record |
|---|---|
| 2025 | OCC control numbers identify the de novo charter and waiver applications |
| 2026-02-12 | OCC granted preliminary conditional approval in Corporate Decision 1365 |
| Before opening | Capital, governance, systems, compliance, pre-opening examination, and other requirements must be completed |
| Within 18 months of preliminary approval | Bank must open or the approval expires, absent the limited extension circumstances stated by OCC |
Source note: Corporate Decision 1365 is the controlling point-in-time source; the OCC Interpretations & Decisions index should be checked for a later final decision.
Comparison checklist
Any comparison with a state MTL, NYDFS trust/BitLicense, industrial bank, credit union, or offshore e-money route should use the applicant’s actual activities and report separately:
- legal entity and regulator;
- preliminary, conditional, final, and operating status;
- activity-specific state-law pre-emption analysis;
- capital and liquidity conditions;
- deposit-insurance status;
- Federal Reserve account and payment-system status;
- elapsed application time and disclosed cost.
This page does not supply cross-route cost, time, or valuation rankings because the cited official sources do not provide a comparable dataset.
SEC / CFTC jurisdiction background is in CFTC vs SEC Cryptocurrency Jurisdiction Dispute. Cross-jurisdiction license comparisons belong in Global VASP Regulatory Comparison Matrix, with status and activity scope kept separate.
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