OCC approves Coinbase national trust charter

Key Takeaways

The record	The OCC applications file lists Coinbase National Trust Company's charter as consummated and effective on Friday, Nov. 6, 2026. An approval is listed for Thursday, April 2.
The business	The April decision allows fiduciary digital-asset custody, mainly for institutions. The trust will not be FDIC-insured, and the OCC said it does not propose to issue stablecoins.
The conditions	For three years the trust must hold at least $60 million of tier 1 capital and a separate pool of liquid assets equal to 180 days of wind-down expenses.
The migration	Coinbase told the OCC it will move custody from its New York state trust over three years. Staking, prime trading and prime financing stay with affiliates.

The Office of the Comptroller of the Currency listed the Coinbase national trust charter as consummated and effective on Friday, Nov. 6, 2026, its applications record shows. Coinbase National Trust Company, in New York, is a subsidiary of Coinbase Global and had only a preliminary conditional approval from Thursday, April 2.

Crypto.news reported on Monday, Nov. 9, that Coinbase announced the completed approval that day. Ryan VanGrack, whom the outlet identified as Coinbase's vice chairman, said, "We’ve spent years asking for clear rules and rigorous oversight, and today’s approval of our national trust charter puts more of our business behind that commitment." The OCC file dates the effective action to Friday, Nov. 6, not to Monday, Nov. 9.

What the Coinbase national trust charter allows

Corporate Decision 1370, signed by Senior Deputy Comptroller Stephen A. Lybarger, grants preliminary conditional approval only. The letter said final authority to commence business under 12 USC 27(a) would wait until preopening requirements were met. The OCC applications record now lists control number 2025-Charter-343449 as consummated and effective. The published interpretations index still shows the April 2 letter as the Coinbase decision. No separate November letter was posted there as of Monday, Nov. 9. In its application, Coinbase called the charter the next step under federal regulation.

The main office is One Madison Avenue, New York, in space leased from Coinbase. The trust will custody digital assets as a fiduciary, chiefly for institutions, and clients may accept, hold and transfer custodied fiat and digital assets. Fiat sits in for-benefit-of accounts at other banks. The OCC required trust-company operations only, and a structure that does not meet the Bank Holding Company Act definition of a bank. The firm will not be FDIC-insured, so the Community Reinvestment Act does not apply.

Staking, Prime Trading and Prime Financing stay with affiliates. The trust may introduce clients to those products as a finder under 12 CFR 7.1002, and it will not provide the services itself. The OCC wrote that the bank does not propose to issue stablecoins, so comments on issuance were irrelevant. A condition still requires conformity with the GENIUS Act if the OCC decides that statute applies.

Capital rules that last three years

The April 2 letter sets conditions for the first three years of operation. The trust must hold at least $60 million in tier 1 capital. The greater of at least 50 percent of that capital, or $30 million, must be eligible liquid assets: unpledged cash, deposits at insured banks maturing within 90 days, or U.S. government obligations maturing within 90 days, and not affiliate debt. A separate pool must cover 180 days of wind-down operating expenses and may not be double-counted. The bank must reassess the totals each quarter.

The OCC received five comments, two from bank trade groups and three from community groups. Commenters questioned the agency's authority, the public file, affiliate enforcement history and resolution of an uninsured trust. The letter calls the activities permissible trust operations and says affiliate enforcement history was too attenuated to justify a denial. It says the review was favorable on management, safety and soundness, and expected profitability, and points to 12 CFR 51 for resolving an uninsured national bank.

The preliminary approval would have expired if the bank had not opened within 18 months of Thursday, April 2, 2026. Friday, Nov. 6, falls inside that window. The OCC granted that preliminary approval on the understanding that the bank will apply for Federal Reserve Bank stock under 12 USC 222. It does not mention a Federal Reserve master account. Material changes to the business plan need 60 days' notice and a written non-objection during the three-year period.

Where Coinbase custody sits now

Coinbase's Oct. 3, 2025 application placed institutional custody at Coinbase Custody Trust Company, a limited-purpose trust the New York State Department of Financial Services chartered in 2018. Coinbase told the OCC it will move that entire book to the national trust over the three-year de novo period. The OCC logged the application on Friday, Oct. 3, 2025, and the comment period in the file ended Monday, Nov. 3, 2025.

Coinbase told the OCC that as of June 30, 2025, it held $245.7 billion under custody, approximately 7 percent of crypto's market value that day, and $425 billion of assets on platform. Those are the company's figures, and they are more than a year older than the effective charter. The April letter notes, on a different measure, that OCC-supervised uninsured national trusts reported $7.0 trillion under administration as of Dec. 31, 2025, including $1.7 trillion in custody and safekeeping.

The letter poses no objection to Rick Schonberg as director and chief executive, or to Alesia Haas as director and chief financial officer. Gregory Tusar and Paul Grewal are listed as directors, and Dana Wagner, Brian Dong and Robert Easton as independent directors. It waives the 12 USC 72 residency rule for Haas, Dong, Wagner and Grewal. Cointelegraph reported on Monday, Nov. 9, that the charter took effect on Friday, Nov. 6, citing the OCC. The same system lists Ripple National TR Bank as effective on Monday, Oct. 26, 2026. The file does not show whether any custody client has moved.

This article is news, not financial advice.