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Coinbase national trust charter takes effect after OCC approval

The OCC completed Coinbase's national trust bank charter on November 6, 2026, after April's conditional approval. It brings the exchange's crypto custody under federal supervision, but allows no deposits or lending, and a community-bank lawsuit contests the policy.

By Zain

Published · 5 min read

Coinbase's US national trust charter took effect on November 6, 2026, after the Office of the Comptroller of the Currency finished its review. It lets the biggest US crypto exchange custody digital assets under federal oversight rather than a single state license.

News of the completed charter came on November 9, when Coinbase announced it. The OCC's licensing records list the chartering of Coinbase National Trust Company as complete, about seven months after the regulator granted a preliminary conditional approval in April, and roughly thirteen months after Coinbase filed for the bank on October 3, 2025. Ryan VanGrack, a Coinbase vice chairman, said the firm had “spent years asking for clear rules and rigorous oversight.”

What the charter actually covers

The charter is narrow. Coinbase National Trust Company can hold digital assets for clients as a fiduciary, mostly large institutions, and run the custody accounts that go with that work. It cannot take retail deposits. It cannot make loans. It will not issue stablecoins directly. In its April decision, control number 2025-Charter-343449, the OCC described a bank that will “engage in operations of a trust company and activities related thereto, including fiduciary activities.”

Coinbase plans to move its existing custody business from Coinbase Custody Trust Company, a New York state trust firm, to the new federal entity over a three-year period. The trust bank will also point clients toward staking, prime trading and prime financing run by other Coinbase units. It acts as a finder for those products. It does not provide them itself. Cash held in custody will sit in “for benefit of” accounts at third-party banks, the OCC said, because the trust bank takes no deposits of its own. According to crypto.news, the regulator set a floor of $60 million in core capital for the new bank. Institutional custody is a different world from self-custody, where individuals hold their own keys.

A full charter, with an asterisk

Several outlets called this a full charter. The OCC's paperwork is more careful. Its April letter granted “preliminary conditional approval only” and said final authorization to open for business would wait until the bank met every preopening requirement. The record dated November 6 marks that second step, not a new power the April decision had not already set out.

One limit stayed in place. The bank does not get automatic access to Federal Reserve payment systems. To join them, it has to apply separately for stock in a Federal Reserve Bank. So the charter brings Coinbase under a federal regulator. It does not make Coinbase a bank in the everyday sense. A federal custodian, yes. A bank, no.

Customers see little change at once. Coinbase keeps its New York state trust charter and its BitLicense while the custody book moves across, so institutions holding assets with the firm today keep the same accounts. Coinbase has not said which clients shift to the federal bank first, or how long each group takes.

Coinbase is not first, and the policy is in court

Coinbase joins a short line. For years, Anchorage Digital was the only crypto firm operating under a full national trust bank charter. Ripple reached final OCC approval on October 26, about two weeks before Coinbase. Circle and Crypto.com hold earlier conditional approvals and have not finished the process.

These charters reflect a wider federal opening to crypto. Washington passed the GENIUS Act in July 2025 to set rules for dollar stablecoin issuers, and the OCC rewrote its bank chartering rule in March 2026. Coinbase's approval is one product of that shift. It is also the part banks dislike most.

The charter route itself is being challenged. The Independent Community Bankers of America sued the OCC on October 2 in the US District Court for the District of Columbia. The trade group argues the regulator is stretching its authority by granting trust charters that cover heavy non-fiduciary work. Its complaint takes aim at the OCC's March 2026 chartering rule and at Interpretive Letter 1176, and asks the court to undo a conditional approval granted to Protego Holdings. The case is unresolved. A ruling against the OCC could unsettle other charters granted under the same rule.

Why institutions care about the badge

Scale is the point. Coinbase held about $245.7 billion in institutional custody assets by the middle of 2025 and $376 billion in total platform assets at the end of the year, according to Crypto Briefing. A federal trust charter gives pension funds, asset managers and banks a single national supervisor to name when they pick a custodian, rather than leaning on New York rules alone. The custody business sits beside the trading operation that drove Coinbase's third-quarter results.

Trust banks are a large, old business. OCC-supervised uninsured national trust banks reported $7.0 trillion in assets under administration as of December 31, 2025, the regulator said in its April letter. Of that, $1.7 trillion was custody and safekeeping and $5.3 trillion was fiduciary accounts. Crypto custody is a sliver of the total today. The charter is a bid to grow the sliver.

What to watch

Three things will show whether the charter means what Coinbase says. First, the migration. Coinbase has three years to shift custody from its New York company to the federal one, and it has not said when the switch completes. Second, the lawsuit. The community bankers' case could reshape the rules the charter rests on. Third, the Federal Reserve. Any move by Coinbase to apply for Fed payment access would point to a bigger aim than custody. For now, the company has not filed for it.

Frequently asked

What did Coinbase get from the OCC?

Coinbase received a national trust bank charter for Coinbase National Trust Company. The charter took effect on November 6, 2026, after a preliminary conditional approval in April. It lets Coinbase hold digital assets for clients as a fiduciary under federal supervision. It does not allow retail deposits, lending or direct stablecoin issuance.

Does the charter make Coinbase a bank?

No. The charter is for a limited-purpose trust bank, not a full commercial bank. Coinbase cannot take retail deposits or make loans under it, and it has no automatic access to Federal Reserve payment systems. To join those systems, the trust bank would have to file a separate application for stock in a Federal Reserve Bank.

Is the OCC's trust charter policy being challenged?

Yes. The Independent Community Bankers of America sued the OCC on October 2, 2026, in a Washington federal court. The group says the regulator is overstepping by granting trust charters that include large non-fiduciary activities. The suit targets the OCC's March 2026 chartering rule. A ruling against the OCC could affect charters already granted.

Sources, and what is behind them

  1. OCC Corporate Decision #1370: Coinbase National Trust Company, Office of the Comptroller of the Currency (April 2, 2026)Filing
  2. Coinbase wins full OCC national trust bank charter, crypto.news (November 9, 2026)Press report
  3. Coinbase Receives OCC Approval for National Trust Bank Charter, Cointelegraph (November 9, 2026)Press report
  4. Coinbase receives full US trust charter from the OCC, Crypto Briefing (November 9, 2026)Press report