Coinbase Wins Final OCC Approval for a National Trust Bank

From application to final approval

Coinbase filed the application on 3 October 2025 and received conditional approval on 2 April 2026. Final authorization depended on preopening requirements, and the OCC record now lists 6 November as the effective date. Rick Schonberg, chief executive of the trust company, called it "an important next chapter" in the company blog post.

The OCC attached specific conditions to the charter. The ones published so far are these:

• At least $60 million in tier 1 capital.
• During the first three years, eligible liquid assets of $30 million or 50% of tier 1 capital, whichever is greater.
• A separate liquid reserve covering 180 days of operating expenses.
• 60 days' written notice to the OCC's Novel Bank Supervisory Office before any significant change to the business plan, and a written no-objection before it takes effect.

The custody business moves in stages. Since 2018 it has sat in Coinbase Custody Trust Company, a limited-purpose trust chartered by the New York Department of Financial Services (NYDFS). The OCC decision gives Coinbase the three-year de novo period to transfer it. NYDFS supervision of Coinbase does not end. In its application Coinbase reported $245.7 billion in assets under custody as of 30 June 2025.

Coinbase has not said when the new entity will begin operating or when client accounts will move (Unchained).

What the charter allows and what it excludes

The charter covers custody. The trust bank holds digital assets and fiat for clients in a fiduciary capacity, keeps client fiat in for-benefit-of accounts at third-party banks and runs two existing products:

• Prime Vault, segregated storage with multi-party computation and a separate on-chain address per client.
• Prime Custody, omnibus storage that lets clients trade while assets stay in custody.

The exclusions matter as much. The trust bank does not take retail deposits, lend or operate fractional reserves. It does not provide staking, Prime Trading or Prime Financing itself. It acts only as a finder that refers custody clients to the Coinbase affiliates offering them. Stablecoin issuance is not in the approved plan, and the OCC described public comments on that point as irrelevant because Coinbase had not proposed it.

Coinbase's own announcement goes further than the approval. It says the charter "lays the foundation for potential future payment and stablecoin services". Any such service needs a change to the business plan, and under the conditions above that change needs OCC clearance first.

Who else holds a federal crypto trust charter

Coinbase joins a short list of crypto firms with final approval. Until December 2025 the only one was Anchorage Digital, chartered in January 2021. The OCC then approved a wave of applications. The statuses below are the latest we found as of 9 November 2026.

Circle plans to custody assets for itself and its affiliates first, with USDC reserves as a later step. Ripple's bank will hold reserves for its RLUSD stablecoin. Coinbase's charter, by contrast, rests on an existing third-party custody business that reported $245.7 billion in assets in its application.

The lawsuit and what it means for the charter

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. The complaint, filed under the Administrative Procedure Act, targets three actions:

1. The OCC's national bank chartering rule of 2 March 2026.
2. Interpretive Letter 1176 from January 2021.
3. The conditional charter granted to Protego Holdings.

ICBA argues that the OCC exceeded its authority under the National Bank Act by chartering firms that do not mainly act as fiduciaries. Its complaint counts 21 national trust charters approved or conditionally approved under the current administration, at least 13 of them for crypto companies. The OCC says its rule clarifies powers trust banks have long held and declined to comment on the case. The court has not ruled.

The suit does not name Coinbase. Our reading is that Coinbase sits closer to the safe side of the dispute than applicants with wider charters. Its charter is narrow, custody is the oldest form of trust activity, and the plan excludes staking, lending and stablecoin issuance. The risk lies in the remedy. If the court vacates the March rule and Interpretive Letter 1176, every crypto charter built on them comes into question, and Bitcoin.com reports analysts' view that holders could face a restructuring. A faster outcome looks unlikely. Federal cases of this kind take months to reach a decision, and an appeal would add more.

For clients, little changes on day one. Institutions using Coinbase custody gain a federally chartered custodian over the next three years. Retail users see no new deposit insurance, no lending product and no new protection on exchange balances. The charter is a US license, so Canadian clients stay under provincial securities rules and FINTRAC, covered in our guide to Ontario and Quebec crypto regulations.