Coinbase National Trust Company Becomes an OCC-Chartered National Trust Bank as Charter Takes Effect on 6 November

Coinbase National Trust Company is now a chartered national trust bank supervised by the Office of the Comptroller of the Currency (OCC). The OCC's Corporate Applications Search record for control number 2025-Charter-343449 lists the charter as "Consummated/Effective" on 6 November 2026, seven months after the agency granted preliminary conditional approval on 2 April 2026 and just over a year after the application was received on 3 October 2025.

The new bank, a wholly owned subsidiary of Coinbase Global, Inc., is headquartered at One Madison Avenue in New York and carries proposed charter number 25390. Under the OCC's April decision, it will hold digital assets in custody as a fiduciary, mainly for institutional clients, and take over the custody business that Coinbase currently runs through a New York-chartered limited purpose trust company.

What the Charter Allows and What It Does Not

The OCC's preliminary decision, published as Corporate Decision 1370, describes the bank as a national trust bank limited to the operations of a trust company and related activities under 12 U.S.C. 27(a). Its core business is digital asset custody in a fiduciary capacity, permitted under 12 U.S.C. 92a because New York law lets state trust companies provide cryptocurrency custody as fiduciaries. The decision also counts as a permit to exercise fiduciary powers once the bank commences business.

Custody customers may accept, hold and transfer custodied fiat currency and digital assets through their custodial accounts. These transactional services are available only to custody customers and only for custodied assets, and fiat currency held in custody sits in "for benefit of" accounts at third-party banks. The bank may also act as a finder, giving its custody clients access to Staking, Prime Trading and Prime Financing products offered by Coinbase affiliates; the OCC states that the bank itself will not provide those underlying services.

The bank does not propose to issue stablecoins. In answering a public comment on that point, the OCC wrote that because no issuance is proposed, the stablecoin arguments were irrelevant to the application. It also noted that the bank will not be an insured depository institution, so the Community Reinvestment Act does not apply, and that it must not meet the Bank Holding Company Act definition of a "bank". Coinbase custody services are currently performed by Coinbase Custody Trust Company, LLC, chartered by the New York State Department of Financial Services, and Coinbase will migrate the whole of that custody business to the national bank over the three-year de novo period.

Conditions That Now Apply

The April approval attached six conditions that the OCC describes as enforceable under 12 U.S.C. 1818. The bank must keep at least $60 million in tier 1 capital, with the greater of 50 percent of tier 1 capital or $30 million held in eligible liquid assets, and must separately hold eligible liquid assets covering 180 days of operating expenses measured on a distressed wind-down basis. It must reassess capital and liquidity every quarter and hold more if its risk profile requires. These capital and liquidity conditions run for the bank's first three years of operation.

Any significant deviation from the approved business plan, including changes to risk and operating limits designed to keep a highly liquid balance sheet, needs 60 days' prior notice to the OCC's Novel Bank Supervision office and a written determination of no objection. New directors and senior executive officers, explicitly including the chief compliance officer, Bank Secrecy Act officer, chief technology officer, chief information security officer and chief trust officer, also need OCC non-objection. A separate condition requires the bank to conform its activities, if necessary, to the GENIUS Act (12 U.S.C. 5901 et seq.) and its implementing regulations as they take effect.

The decision names the initial board and management: Rick Schonberg as director and chief executive officer, Alesia Haas as director and chief financial officer, Gregory Tusar and Paul Grewal as directors, and Dana Wagner, Brian Dong and Robert Easton as independent directors. The OCC waived the director residency requirement of 12 U.S.C. 72 for four of them.

Context and What Comes Next

Coinbase is one of a group of crypto firms that have sought OCC trust charters since December 2025, when the agency issued conditional approvals for companies including BitGo, Fidelity Digital Assets, Paxos, Ripple and Circle's proposed First National Digital Currency Bank. The OCC's amended chartering rule at 12 CFR 5.20, published at 91 FR 9977 on 2 March 2026, took effect on 1 April 2026, the day before the Coinbase decision. The OCC received five public comments on the Coinbase application, from two bank trade groups and three community groups, and rejected arguments about its chartering authority, the bank's affiliates' enforcement history and its ability to resolve an uninsured bank.

For institutional custody clients, the practical change is that Coinbase's custody operation moves, over up to three years, from New York state supervision of the trust company to federal OCC supervision of the national bank. Under the decision, the bank is expected to apply for stock in a Federal Reserve Bank under 12 U.S.C. 222. The OCC will supervise compliance with Bank Secrecy Act and sanctions requirements and has said it will monitor for compliance with federal securities laws to the extent the bank's activities touch them. Any move into stablecoin issuance or other activities outside the approved plan would first need the OCC's written non-objection under the business-plan condition.