--- title: OCC National Trust Bank Charters for Digital-Asset Firms · 2025–2026 Verified Update aliases: - occ-crypto-charter-2025 - occ-il-1183 - anchorage-digital-bank-charter - custodia-occ-vs-wyoming-spdi - bitwise-circle-occ-application - state-chartered-trust-arbitrage - occ-crypto-custody-clarification - federal-vs-state-crypto-bank domain: fintech created: 2026-05-25 last_updated: 2026-07-30 last_tended: 2026-07-30 review_by: 2026-11-25 confidence: certain tags: [fintech, regulatory, usa, 2025-reset, occ, bank-charter, anchorage, custodia, circle, bitwise, spdi] status: active sources: - "https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf" - "https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html" - "https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/index-interpretations-and-decisions.html" - "https://www.occ.treas.gov/topics/charters-and-licensing/digital-assets-licensing-applications/index-digital-assets-licensing-applications.html" - "https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-actions/2026/cd1365.pdf" - "https://occ.treas.gov/news-issuances/news-releases/2021/nr-occ-2021-6.html" - "https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/scl2026-01.pdf" - "https://www.supremecourt.gov/docket/docketfiles/html/public/26-62.html" --- # OCC National Trust Bank Charters for Digital-Asset Firms · 2025–2026 Verified Update ## TL;DR OCC Interpretive Letter 1183 was issued on **March 7, 2025**, not March 27. It rescinded IL 1179's supervisory non-objection process and reaffirmed the permissibility, for OCC-supervised banks, of the activities described in IL 1170, 1172 and 1174. It did not itself approve a new charter or guarantee an applicant access to a Federal Reserve master account. The verified charter record changed materially later: the OCC conditionally approved five national trust bank applications on December 12, 2025 and granted Bridge National Trust Bank preliminary conditional approval on February 12, 2026. “Conditional approval,” “final approval to commence business,” and appearance in the active-institution register are separate statuses. In the separate Custodia litigation, Tenth Circuit merits and rehearing proceedings have ended, but a Supreme Court certiorari petition remains pending in No. 26-62 as of 2026-07-30. ## Wiki route This entry sits under [[fintech/INDEX|fintech index]] as the evidence-first companion to [[fintech/occ-trust-bank-charter-federal-stablecoin-arbitrage|OCC trust-bank charter]]. Read it with [[fintech/genius-act-501-actual-implementation|GENIUS Act implementation]] and [[exchanges/us-crypto-licensing-multi-layer-system|US crypto licensing multi-layer]]. ## Why this entry exists This entry separates four questions that are often collapsed: whether an activity is permissible for an OCC-supervised bank, whether the OCC has conditionally approved an application, whether the institution has received final authority to commence business, and whether another regulator or state law still applies. The source of truth for application and approval status is the OCC record, not an applicant's announcement. ## OCC charter background · the four-letter chain The table below is based on [IL 1183 and the three letters it identifies](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf). These letters address activities of national banks and federal savings associations; they are not blanket licences for any crypto company. | Letter | Date | What it authorized | |---|---|---| | IL 1170 | 2020-07 | National banks may provide cryptocurrency custody services for customers | | IL 1172 | 2020-09 | National banks may hold reserves backing stablecoins | | IL 1174 | 2021-01 | National banks may use independent node verification networks and stablecoins for payment activities | | IL 1179 | 2021-11 | Required a bank to obtain written supervisory non-objection before engaging in the activities described in IL 1170, 1172 or 1174 | IL 1179 changed the supervisory process for the specified activities. The letter did not state that all new charter applications were frozen, so this entry does not use “charter hold” as a legal status. The 2025 **OCC Interpretive Letter 1183** (March 7, 2025): - **Reaffirms** IL 1170, 1172, and 1174 as continuing to state OCC's view of the permissibility of crypto custody, stablecoin reserves, and node-operator activities. - **Removes the IL 1179 prior-non-objection requirement** and replaces it with normal-course supervisory engagement (the regime that applies to every other permissible national-bank activity). - States that the OCC will examine those activities through its ongoing supervisory process and expects safe, sound and fair conduct in compliance with applicable law. IL 1183 does not set an application timeline, capital amount, approval presumption or Federal Reserve account entitlement. ## Anchorage Digital Bank · the precedent case The OCC [conditionally approved Anchorage Trust Company's conversion](https://occ.treas.gov/news-issuances/news-releases/2021/nr-occ-2021-6.html) to Anchorage Digital Bank, N.A., a national trust bank, on January 13, 2021. The approval and operating agreement imposed institution-specific capital, liquidity, risk-management and BSA/AML conditions. The OCC issued a consent order in 2022 over BSA/AML deficiencies. On February 9, 2026, it [terminated the 2021 operating agreement](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/scl2026-01.pdf) after determining that the bank had complied with its actionable articles and that corrective actions were effective and sustainable. That termination does not establish that every proposed product is approved; product authority and any GENIUS Act issuer status must be checked separately. ## Custodia Bank · the Wyoming SPDI counter-pattern Custodia is a Wyoming-chartered special purpose depository institution (SPDI). The Federal Reserve Board [denied its membership application](https://www.federalreserve.gov/newsevents/pressreleases/orders20230127a.htm) in January 2023. On October 31, 2025, the Tenth Circuit [affirmed](https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111327582.pdf) that Reserve Banks have discretion to reject an otherwise eligible institution's master-account request, and rehearing was denied on March 13, 2026. Those appellate-court proceedings are complete. Separately, the [Supreme Court docket for No. 26-62](https://www.supremecourt.gov/docket/docketfiles/html/public/26-62.html) records a certiorari petition filed July 10 and docketed July 14, 2026, with a response due August 13. The petition—not the Tenth Circuit appeal—is pending as of 2026-07-30. The following comparison is grounded in the [OCC charter decisions](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/index-interpretations-and-decisions.html), the [Wyoming SPDI description](https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions), the Tenth Circuit opinion and the Supreme Court docket. It deliberately omits generic approval times, capital ranges and political ratings because those depend on the application and conditions. | Dimension | OCC national trust bank | Wyoming SPDI | |---|---|---| | Chartering authority | OCC under federal banking law | Wyoming Division of Banking under Wyoming law | | Permitted scope | Trust-company operations and related activities specified in the charter, business plan and conditions | Fully reserved banking plus activities permitted by Wyoming law; fiat customer deposits must be backed 100% or more by unencumbered liquid assets | | Deposit insurance | May be uninsured; verify the institution record | FDIC insurance is not required by Wyoming for an SPDI, though an SPDI may seek it | | Reserve Bank account | Not created by an OCC conditional approval; Federal Reserve requirements and any application still matter | Statutory eligibility did not compel access in Custodia; the Tenth Circuit upheld Reserve Bank discretion, and a certiorari petition is pending | | State licensing | Federal pre-emption is activity- and law-specific; verify current OCC interpretation and the product | State-by-state licensing and exemptions remain a separate analysis | | Stablecoin issuance | Requires authority in the charter/business plan plus compliance with applicable stablecoin law and conditions | Wyoming charter status alone does not prove federal GENIUS Act issuer status or nationwide offering authority | ## Verified OCC decisions · status as of July 2026 The rows below come from the OCC's [December 12, 2025 release](https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html), [Bridge decision](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-actions/2026/cd1365.pdf), and [interpretations-and-decisions index](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/index-interpretations-and-decisions.html). They describe OCC actions, not an inference about when each institution may begin every proposed activity. | Institution | OCC action | Decision date | What the record establishes | |---|---|---|---| | First National Digital Currency Bank, N.A. | Preliminary conditional approval for a new national trust bank | 2025-12-12 | Conditional approval; final approval to commence business remains a separate step | | Ripple National Trust Bank, N.A. | Preliminary conditional approval for a new national trust bank | 2025-12-12 | Conditional approval subject to the OCC's stated conditions | | BitGo Bank & Trust, N.A. | Conditional approval to convert a state trust company | 2025-12-12 | Conversion approval subject to conditions and completion requirements | | Fidelity Digital Assets, N.A. | Conditional approval to convert a state trust company | 2025-12-12 | Conversion approval subject to conditions and completion requirements | | Paxos Trust Company, N.A. | Conditional approval to convert a state trust company | 2025-12-12 | Conversion approval subject to conditions and completion requirements | | Bridge National Trust Bank, N.A. | Preliminary conditional approval for a new national trust bank | 2026-02-12 | Preliminary conditional approval, not by itself final authority to commence business | The OCC also maintains a [digital-assets licensing-applications page](https://www.occ.treas.gov/topics/charters-and-licensing/digital-assets-licensing-applications/index-digital-assets-licensing-applications.html). A pending application, preliminary conditional approval, final approval, completed conversion and active-institution listing should not be treated as interchangeable statuses. This entry therefore omits unverified applicant counts, backlog records and projected approval dates. ## What a national trust charter does—and does not—establish An OCC approval establishes the trust-company powers, related activities and conditions described in the decision, operating agreement and approved business plan. It does not create an unrestricted federal “crypto bank” licence. - **Custody and payment activities:** IL 1170, 1172 and 1174 address activities that OCC-supervised banks may conduct, subject to safe-and-sound operation and applicable law. IL 1183 removed the special IL 1179 prior-non-objection process; it did not remove ordinary supervision. - **Stablecoin issuance:** status as a permitted payment stablecoin issuer under the [GENIUS Act](https://www.congress.gov/119/plaws/publ27/PLAW-119publ27.pdf) is a separate statutory and supervisory question. The OCC's [2026 proposed implementation rule](https://www.occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-3.html) was a proposal, not proof that any named institution had completed all issuer-approval steps. - **Federal Reserve services:** an OCC charter or conditional approval does not automatically supply a master account or Fedwire access. Federal Reserve eligibility, review and any separate application remain relevant. - **State law:** federal pre-emption is specific to the institution, activity and state-law requirement. The OCC's current interpretations and the actual product footprint must be checked; “one charter replaces every state licence” is too broad. - **Deposit insurance:** a national trust bank may be uninsured. Charter status is not evidence that customer balances or stablecoin reserves are FDIC-insured. ## OCC IL 1183 · exact scope [IL 1183](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf) is a one-page interpretive letter. It: 1. rescinds IL 1179; 2. reaffirms IL 1170, 1172 and 1174; 3. states that OCC-supervised banks may engage in the activities addressed by those letters without obtaining supervisory non-objection first; and 4. says the OCC will examine those activities through its normal supervisory process. The letter does not create a new charter category, approve a particular application, prescribe an application timetable, grant Federal Reserve access, decide deposit-insurance treatment or waive institution-specific capital, liquidity, governance, BSA/AML and risk-management conditions. ## Federal and state paths are separate legal products The comparison below is grounded in the OCC decisions above, the [Wyoming SPDI framework](https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions), and the [NYDFS virtual-currency framework](https://www.dfs.ny.gov/virtual_currency_businesses). It is not a speed, cost or approval-probability ranking. | Path | Charter or authorization | Verified boundary | |---|---|---| | OCC national trust bank | Federal national trust-bank charter or conversion | Powers and conditions are decision-specific; a conditional approval is not automatically final authority to commence business | | Wyoming SPDI | State depository charter under Wyoming law | Wyoming requires fiat customer deposits to be backed by at least 100% unencumbered liquid assets; Federal Reserve access remains a separate question | | New York virtual-currency business | BitLicense or New York banking-law charter with DFS approval | Authorization and approved activities are entity-specific; a New York authorization is not an OCC charter | The choice among these paths cannot be reduced to a generic “regulatory arbitrage” score. Product scope, deposit-taking, custody structure, geographic reach, reserve model and access to payment rails have to be tested against the actual charter and licences. ## Verification checklist Before describing a firm as a federally chartered digital-asset bank or stablecoin issuer: 1. check the OCC decision and its date; 2. distinguish preliminary or conditional approval from final approval to commence business; 3. check the OCC active-institution record and any subsequent order or operating agreement; 4. verify that the proposed activity is within the approved business plan and conditions; 5. verify any separate GENIUS Act issuer approval or rule requirement; 6. check Federal Reserve access independently; and 7. test state licensing and pre-emption product by product. For the broader state-licensing context see [[exchanges/us-crypto-licensing-multi-layer-system|US crypto licensing multi-layer]] and [[fintech/global-stablecoin-regulatory-five-pole-matrix|five-pole matrix]]. ## Related - [[fintech/INDEX|fintech index]] - [[fintech/regulatory-reset-2025-usa-crypto-policy|US 2025 regulatory reset]] - [[fintech/genius-act-501-actual-implementation|GENIUS Act enacted-text implementation]] - [[fintech/treasury-stablecoin-policy-2025|Treasury 2025 stablecoin framework]] - [[fintech/occ-trust-bank-charter-federal-stablecoin-arbitrage|OCC trust-bank charter (mechanism)]] - [[fintech/cftc-sec-crypto-jurisdiction|CFTC vs SEC jurisdiction]] - [[fintech/global-stablecoin-regulatory-five-pole-matrix|five-pole matrix]] - [[fintech/mica-overview|EU MiCA overview]] - [[fintech/regulatory-window-strategic-acquisition|regulatory window M&A]] - [[fintech/wall-street-crypto-network-neutrality|Wall Street network neutrality]] - [[fintech/national-license-private-stablecoin-with-dpi-export|national license private stablecoin]] - [[fintech/ripple-rlusd-stablecoin|RLUSD]] - [[fintech/paypal-pyusd-stablecoin|PayPal PYUSD]] - [[fintech/tether-business-model-short-treasury-yield|Tether business model]] - [[fintech/blackrock-buidl-tokenized-mmf-overview|BlackRock BUIDL]] - [[business/larry-fink-blackrock-digital-asset-template|Larry Fink template]] - [[business/brian-armstrong-coinbase-public-company-template|Brian Armstrong Coinbase template]] - [[business/hester-peirce-sec-regulatory-pivot-case|Hester Peirce pivot]] - [[exchanges/us-crypto-licensing-multi-layer-system|US crypto licensing multi-layer]] - [[exchanges/INDEX|exchanges index]] ## Sources - [OCC Interpretive Letter 1183 (March 7, 2025)](https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2025/int1183.pdf) - [OCC conditionally approves five national trust banks (December 12, 2025)](https://www.occ.treas.gov/news-issuances/news-releases/2025/nr-occ-2025-125.html) - [Bridge National Trust Bank preliminary conditional approval (February 12, 2026)](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-actions/2026/cd1365.pdf) - [OCC digital-assets licensing applications](https://www.occ.treas.gov/topics/charters-and-licensing/digital-assets-licensing-applications/index-digital-assets-licensing-applications.html) - [OCC interpretations and decisions index](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/index-interpretations-and-decisions.html) - [Anchorage conversion conditional approval (January 13, 2021)](https://occ.treas.gov/news-issuances/news-releases/2021/nr-occ-2021-6.html) - [Anchorage operating-agreement termination (February 9, 2026)](https://www.occ.treas.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/scl2026-01.pdf) - [Federal Reserve denial of Custodia membership application (January 27, 2023)](https://www.federalreserve.gov/newsevents/pressreleases/orders20230127a.htm) - [Tenth Circuit opinion in Custodia Bank v. Federal Reserve (October 31, 2025)](https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111327582.pdf) - [U.S. Supreme Court docket No. 26-62, Custodia Bank, Inc. v. Federal Reserve Board of Governors, et al.](https://www.supremecourt.gov/docket/docketfiles/html/public/26-62.html) - [Wyoming Division of Banking SPDI framework](https://wyomingbankingdivision.wyo.gov/banks-and-trust-companies/special-purpose-depository-institutions) - [NYDFS virtual-currency business framework](https://www.dfs.ny.gov/virtual_currency_businesses) - [GENIUS Act, Public Law 119-27](https://www.congress.gov/119/plaws/publ27/PLAW-119publ27.pdf) - [OCC Bulletin 2026-3: proposed GENIUS Act implementation rule](https://www.occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-3.html)