
Coinbase gets its national trust bank charter: what the OCC approved and what it did not
By Yash Malviya·
The OCC gave final approval on November 6, 2026 for Coinbase National Trust Company, a federal trust bank that will take over the exchange's institutional crypto custody. It can hold assets as a fiduciary. It cannot take deposits or lend, and it must keep at least $60 million in tier 1 capital.
Coinbase said on November 9, 2026 that the Office of the Comptroller of the Currency has given final approval for Coinbase National Trust Company, a federally chartered national trust bank that will take over the company's institutional crypto custody business. The OCC's sign-off came on Friday, November 6, 2026, according to Unchained and Cointelegraph, which cited the regulator's filing records, seven months after a preliminary conditional approval dated April 2, 2026. A national trust charter lets the new entity hold client assets as a fiduciary under federal supervision. It does not make Coinbase a deposit-taking bank, and it comes with a capital floor and a three-year migration plan written into the OCC's decision.
What the OCC actually approved
The clearest description of the bank is in the OCC's own preliminary approval, Corporate Decision #1370, dated April 2, 2026 and addressed to Coinbase's counsel at Covington & Burling. The OCC said it had reviewed an application "to establish a new national trust bank, which will engage in operations of a trust company and activities related thereto, including fiduciary activities, with the title of Coinbase National Trust Company, New York, New York." The application was filed under OCC control number 2025-Charter-343449; Cointelegraph reported that Coinbase applied in October 2025.
The decision describes the business plainly. The bank "plans to provide digital asset custody services as a fiduciary, primarily for institutional clients, and related activities, including certain transactional services for custody customers in connection with their custodied assets." Those transactional services let custody customers accept, hold and transfer fiat currency and digital assets within their custodial accounts, and fiat held in custody sits in for-benefit-of accounts at third-party banks.
The April letter was explicit that it was not the end of the process: "Final approval and authorization pursuant to 12 USC 27(a) for the Bank to commence business will not be granted until all preopening requirements are met." That final step is what Coinbase announced on November 9. Unchained reported that the company did not say when the trust company will begin operating or when custody accounts will move to it.
What a national trust bank can and cannot do
A national trust charter is narrower than a full bank charter. Unchained quoted Austin Campbell, founder of Zero Knowledge Group, explaining the limits on its Bits + Bips podcast in August: a traditional bank lends out customer deposits, but "a trust bank cannot do that." Instead, "you can take in customer assets, you can hold them, and you can manage the reserves of a stablecoin." Decrypt reported that when the conditional approval came in April, Coinbase said it was not becoming a commercial bank and would not take retail deposits or engage in fractional reserve banking.
“has always pursued best-in-class regulatory oversight and that is what we are getting with the OCC.”
That distinction matters for anyone reading "Coinbase bank" headlines. There is no lending book, no checking account and no deposit franchise in this charter. There is custody, which Coinbase said in its announcement it has provided for more than 14 years, now under a federal examiner rather than only a state one. For the mechanics of what a bank with deposits does differently, see how banks make money.

The conditions attached
The OCC's April decision lists conditions that carry through the bank's first three years of operation. Condition 4 is the one with a number: "The Bank must maintain a minimum of $60 million in tier 1 capital of which the greater of at least 50 percent of its tier 1 capital or $30 million must be held in Eligible Liquid Assets." The bank must also assess the appropriateness of its capital and liquidity quarterly and hold more if it determines that is necessary. Other conditions require OCC no-objection before certain changes during the de novo period.
The decision also fixes how the business moves. Coinbase's custody services are currently performed by Coinbase Custody Trust Company, a limited purpose trust company chartered by the New York State Department of Financial Services in 2018. The OCC wrote that "Coinbase will migrate the entirety of this custody business from CCTC to the Bank over the three-year de novo period." The new bank may also act as a finder, giving custody clients access to staking, prime trading and prime financing offered by Coinbase affiliates, but the OCC noted the bank "will not be providing the underlying Staking, Prime Trading, and Prime Financing services itself."
Why Coinbase wanted a federal charter
Coinbase's stated reason is uniformity. Unchained reported that the company's announcement said the charter brings "clear and consistent federal uniformity" to its custody business. In an emailed statement, Vice Chair Ryan VanGrack said the company had "spent years asking for clear rules and rigorous oversight," and that the approval "puts more of our business behind that commitment." Chief Policy Officer Faryar Shirzad said Coinbase "has always pursued best-in-class regulatory oversight and that is what we are getting with the OCC."
The company also said the charter "opens the door to expanded custody capabilities" and "lays the foundation for potential future payment and stablecoin services," per Unchained, without describing those services or giving a timeline. Stablecoin reserves are exactly the kind of asset a trust bank can hold, as Campbell described; what a stablecoin is and how reserves back it is covered in our stablecoin explainer.
Who else holds one
Coinbase joins a list. Cointelegraph reported that Ripple, Circle, BitGo, Fidelity Digital Assets and Paxos already hold OCC national trust charters, that Crypto.com and Stripe-owned Bridge have conditional approvals, and that Kraken and EDX Markets are still pursuing charters. Decrypt reported that Circle won final approval in July for a trust bank managing the reserves behind USDC and Ripple received final approval in October for the bank behind RLUSD.
The approvals are contested. Decrypt reported that Senator Elizabeth Warren has argued the OCC's crypto charter approvals, including Coinbase's, are illegal, and that the Independent Community Bankers of America has sued the OCC to stop crypto firms entering banking through what it describes as a side door. That litigation is the main open risk to the charter's value.
What to watch
The dates that matter next are the ones Coinbase has not given: when the bank opens for business, and when the first custody accounts move across from the New York entity. The OCC's three-year de novo period runs from opening, and the $60 million capital floor applies throughout it. The ICBA suit against the OCC is the other item to track, because a court ruling on trust charters would apply to every name on the list above, not just Coinbase.
Frequently asked questions
What is the Coinbase national trust bank charter?
It is a federal charter from the Office of the Comptroller of the Currency for Coinbase National Trust Company, a national trust bank that will provide digital asset custody as a fiduciary, mainly for institutional clients. The OCC gave preliminary conditional approval on April 2, 2026 and, according to Coinbase and OCC records cited by Unchained and Cointelegraph, final approval on November 6, 2026.
Can Coinbase National Trust Company take deposits or make loans?
No. A national trust charter is narrower than a full bank charter. It allows the entity to hold and manage customer assets but not to lend out deposits, as Unchained explained. Decrypt reported that Coinbase said in April it was not becoming a commercial bank and would not take retail deposits.
What conditions did the OCC put on Coinbase's charter?
Condition 4 of OCC Corporate Decision #1370 requires the bank to maintain a minimum of $60 million in tier 1 capital, with the greater of 50 percent of that or $30 million held in eligible liquid assets, assessed quarterly. The conditions apply through the bank's first three years of operation.
What happens to Coinbase's existing custody business?
Custody is currently performed by Coinbase Custody Trust Company, a New York limited purpose trust company. The OCC's decision says Coinbase will migrate the entirety of that custody business to the new national trust bank over the three-year de novo period. Coinbase has not given a start date, per Unchained.
Which other crypto companies have OCC trust charters?
Cointelegraph reported that Ripple, Circle, BitGo, Fidelity Digital Assets and Paxos hold national trust charters, Crypto.com and Bridge have conditional approvals, and Kraken and EDX Markets are still applying. Decrypt reported that the Independent Community Bankers of America has sued the OCC over the approvals.
Sources
What each one is, and whose it is.
- 1
Corporate Decision #1370: Coinbase National Trust Company, preliminary conditional approval, Office of the Comptroller of the Currency (April 2, 2026)
DocumentationIndependent of the vendor - 2
Coinbase Wins Final OCC Approval to Charter a National Trust Company for Crypto Custody, Unchained (November 9, 2026)
Press reportIndependent of the vendor - 3
Coinbase's US national trust bank charter takes effect, Cointelegraph (November 9, 2026)
Press reportIndependent of the vendor - 4
Coinbase Joins Circle, Ripple With Final OCC Approval for Federal Trust Bank Charter, Decrypt (November 9, 2026)
Press reportIndependent of the vendor