Crypto companies are flooding federal regulators with bank charter applications, but they're not building the next JPMorgan. Instead, a wave of institutional players including Circle, Ripple, Coinbase, and others are pursuing specialized trust bank charters to lock down custody, settlement, and asset-management roles under federal supervision.

What's Driving the Crypto Bank Charter Surge?

The Office of the Comptroller of the Currency (OCC), which oversees national banks in the United States, revealed it received 40 new bank charter applications over roughly the past 18 months, with 23 of those incorporating digital-asset activities. That represents an eightfold increase compared to crypto-related filings over the previous four years. The shift signals a fundamental change in how crypto infrastructure is being regulated and legitimized.

The key insight: most applicants are not seeking commercial banking licenses to offer checking accounts or mortgages. Instead, they're targeting national trust bank charters, a narrower federal vehicle designed for fiduciary, asset administration, and custodial responsibilities. A national trust bank operates under strict federal oversight but focuses on protecting and managing client assets rather than taking retail deposits or extending consumer loans.

"The core objective behind these filings is establishing a direct federal regulatory shield for crypto's financial plumbing," according to regulatory analysis of the OCC's filings.

Regulatory Analysis, OCC Charter Filings

Which Crypto Companies Are Pursuing These Charters?

The regulatory pipeline includes several major players at different stages. In December 2025, the OCC granted conditional approvals for de novo national trust-bank applications from Circle's First National Digital Currency Bank and Ripple National Trust Bank. Simultaneously, the agency approved charter conversions for BitGo Bank & Trust, Fidelity Digital Assets, and Paxos Trust Company. Other applicants include Coinbase National Trust Company, Crypto.com's proposed Foris DAX National Trust Bank, Trump-backed World Liberty, and Morgan Stanley, which is seeking a US trust bank charter to scale its institutional custody arm.

It's important to note that conditional approval establishes operational requirements but does not immediately grant the right to open for business. Filings move sequentially through pending status, conditional approval, and finalized authority to operate. Securing a trust charter also does not grant automatic access to Federal Deposit Insurance Corporation (FDIC) deposit insurance for retail traders.

How Trust Banks Differ From Traditional Commercial Banks

Understanding the distinction between trust charters and commercial banking licenses is crucial to grasping why crypto firms are pursuing this path. Unlike commercial institutions, national trust banks generally skip consumer lending, refrain from taking retail deposits, and operate without FDIC insurance. This structure might sound limiting, but it actually aligns perfectly with what crypto custody providers and stablecoin issuers need to do.

• Fiduciary Oversight: Trust banks operate under strict fiduciary duty, meaning they must prioritize client interests above all else when managing assets and private keys.
• Custody and Asset Management: These institutions focus on digital asset safekeeping, corporate trust management, investment administration, and targeted payment settlement rather than consumer banking services.
• Federal Supervision: National trust banks remain bound by their specific business plans and agency-imposed conditions, providing institutional clients with audited, federally supervised partners to hold private keys and manage customer property.
• Stablecoin Reserve Management: Trust charters allow firms to manage the backing funds for stablecoins, which are cryptocurrency tokens designed to maintain a stable value relative to a reference asset like the US dollar.

The OCC has repeatedly clarified that national banks and federal savings associations possess the authority to hold digital assets in custody, manage stablecoin backing funds, and utilize distributed ledger technologies for permissible payment flows, provided appropriate risk management systems are active. Its 2025 interpretive guidance removed the requirement for firms to obtain prior supervisory non-objection before launching those specific operations.

What Does This Mean for Institutional Crypto Infrastructure?

Citi, one of the world's largest financial institutions, is moving in parallel with this trend. The bank unveiled its Custody+ platform and confirmed plans to launch institutional digital asset custody later in 2026, beginning with Bitcoin (BTC). Rather than running Bitcoin custody through a separate product, Citi plans to build the service on its common digital asset architecture, allowing institutional clients to access traditional securities and cryptocurrency custody through the same framework.

Custody+ replaces a standard custody model with modular services that clients can adapt to their own operating systems and workflows. Digital asset custody will sit alongside real-time settlement, liquidity management, foreign exchange services, and market data. An asset manager holding Bitcoin and conventional securities could use one Citi environment for custody services instead of dealing with separate operating systems.

"Custody+ is the product of a multi-year commitment to building infrastructure that matches the speed of our clients' strategies," stated Amit Agarwal, head of Custody at Citi Investor Services.

Amit Agarwal, Head of Custody, Citi Investor Services

Citi's infrastructure is powered by its Single Event Processing (SEP) technology, which processes asset-servicing transactions through one continuous flow across the bank's domestic and international custody networks. More than 80% of the bank's total event volume is now handled in real time. Within the United States, SEP has cut processing times for voluntary corporate actions by as much as 92%, while 96% of voluntary events are completed in under two hours.

How Institutional Custody Is Reshaping Crypto's Backend

For individual retail users, this shift will not manifest as a wave of new FDIC-insured crypto checking accounts. Instead, the changes will happen behind the scenes: institutional trust banks storing exchange-held assets, regulated entities managing stablecoin reserves, or specialized trust institutions powering payment rails behind retail apps. A tool offering AI-managed portfolios for US crypto traders serves as the front-end user touchpoint, while a national trust bank operates out of sight, managing the underlying custody, asset segregation, and regulatory compliance that keep the system running.

Securing a trust charter elevates a platform's institutional credibility, but it does not convert a digital asset company into a traditional commercial bank. The OCC has widened the path without erasing the divide between specialized trust entities and commercial deposit institutions. The statutory boundary remains intact, with the OCC's final rule explicitly limiting broader operational scope to trust-related activities, leaving nationwide retail lending out of the picture.

Citi's investment in this infrastructure is substantial. The bank invests more than $2 billion annually in its Services platform strategy, with spending focused on speed, scale, and availability. Chris Cox, head of Investor Services at Citi, emphasized that the bank is combining its international network with data and technology to support institutions that need continuous market access, transparency, and precise transaction processing.

The 23-of-40 figure confirms that crypto firms want a permanent footprint within federal banking structures. Rather than building consumer branches, they are constructing a regulated foundation for holding assets, supporting stablecoin reserves, and settling transactions, establishing institutional credibility while bypassing the traditional consumer banking model. This shift moves crypto's core infrastructure directly under federal banking supervision, a development that could reshape how digital assets are stored, managed, and transferred for years to come.