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Coinbase wins a federal trust bank charter

Coinbase wins a federal trust bank charter

Rule Changes

The OCC gave final approval to Coinbase National Trust Company, moving its custody business from New York oversight to Washington over three years

Yesterday: Charter terms reported: three-year transfer, $60M capital floor

Overview

Updated 3 hours ago

Coinbase has held its customers' crypto under a New York state trust charter since October 2018. On Nov. 6, the Office of the Comptroller of the Currency (OCC) granted its replacement, Coinbase National Trust Company, a full federal trust bank charter.

The charter covers custody, not banking. The trust company can hold digital assets for clients and move cash and crypto between custody accounts. It cannot take deposits, make loans, or offer federal deposit insurance on crypto holdings.

Why it matters

Crypto custody is shifting from state-by-state licensing to one federal supervisor, with bank-style capital rules and no deposit insurance behind it.

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Key Indicators

$376.6B
Customer crypto and stablecoins on Coinbase's platform
Companywide figure as of Sept. 30, 2026; Coinbase has not said how much of it moves to the trust bank.
$60M
Minimum core capital for the trust company
Required during the bank's first three years under the OCC's April decision.
180 days
Operating costs covered by a separate liquid asset pool
The OCC requires the buffer to cover a wind-down scenario.
3 years
Phase-in to move New York custody business to the federal bank
Clients transfer account by account from the New York trust company to the federal one.

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People Involved

RS
Rick Schonberg
Chief executive of Coinbase National Trust Company
Leads the newly chartered federal trust bank
 Brian Armstrong
Brian Armstrong
Co-founder and chief executive of Coinbase
Runs the exchange that owns the new trust bank
RR
Rebeca Romero Rainey
President and chief executive of the Independent Community Bankers of America
Opposing the approval and challenging the OCC's chartering rule in court

Organizations Involved

Coinbase Global
Coinbase Global
Publicly traded cryptocurrency exchange and financial infrastructure company
Owns the newly chartered federal trust bank

The largest U.S. crypto exchange, now also the parent of a nationally chartered trust bank.
Office of the Comptroller of the Currency
Office of the Comptroller of the Currency
Federal Agency
Chartered the trust bank and faces a lawsuit over its chartering rule

The Treasury Department bureau that charters and supervises national banks and federal trust banks.
Independent Community Bankers of America
Independent Community Bankers of America
Trade association
Opposing Coinbase's charter and suing the OCC

A trade group for U.S. community banks that argues federal trust charters let crypto firms skip bank-level regulation.

Timeline

October 2018 November 2026

9 events Latest: Yesterday
Tap a bar to jump to that date

  1. Charter terms reported: three-year transfer, $60M capital floor

    Latest Report

    Details emerge on the phase-in from New York supervision, the capital minimum and the no-deposit-insurance limit.

  2. Coinbase announces the charter; ICBA objects

    Statement

    Coinbase says custody now sits under one federal framework. The community bankers group calls the approval misguided.

  3. OCC grants Coinbase final charter

    Regulatory

    The conditional status is lifted and Coinbase National Trust Company becomes a fully chartered federal trust bank.

  4. Ripple's trust charter takes effect

    Regulatory

    Another crypto firm begins operating under a federal trust charter granted by the OCC.

  5. Community bankers sue the OCC

    Legal

    The ICBA challenges the OCC's trust chartering rule in federal court and asks it to void Protego's conditional approval.

  6. Circle gets final approval for its national trust bank

    Regulatory

    Circle wins a federal trust charter for oversight of USDC reserves, an early template for Coinbase's bid.

  7. OCC grants conditional approval

    Regulatory

    Provisional status lets Coinbase build compliance systems and staff the bank before opening.

  8. Coinbase applies for a federal trust charter

    Filing

    Coinbase submits its application to the OCC for Coinbase National Trust Company.

  9. Coinbase custody arm gets a New York trust charter

    Charter

    The New York State Department of Financial Services grants a limited-purpose trust charter that Coinbase's custody business operates under.

Scenarios

1

Custody clients move to the federal trust on schedule

Likely Resolves by End of 2029

Discussed by: Coinbase's charter application and OCC's April decision, both of which set a three-year phase-in

The OCC decision describes a plan to move the entire New York trust company's custody business into the federal bank over three years, with clients transferring account by account. Coinbase has given no date for the first group to move. The open question is scheduling: institutions with existing custody arrangements need to know when their accounts change hands, and any delay pushes the migration past the three-year window.

2

A federal court voids the OCC's trust chartering rule

Possible Resolves by End of 2027

Discussed by: The Independent Community Bankers of America, which filed suit on Oct. 2, 2026

The ICBA argues the OCC lacks statutory authority to charter trust banks that offer deposit-like services without deposit insurance. A ruling against the agency would put Coinbase's charter, along with Circle's and Ripple's, in question. The case turns on how broadly the OCC can read its trust powers, not on Coinbase's conduct.

3

The trust bank moves into stablecoin issuance or payments

Possible Resolves by End of 2027

Discussed by: Coinbase's charter filing, which lists digital asset payments and blockchain programs as areas it plans to explore

The GENIUS Act opened a path for federal trust banks to issue compliant stablecoins, and Coinbase's application names payments as a future line of business. For now the charter is custody-only. An announcement that the trust company itself issues a stablecoin or settles client payments would mark a real expansion of what the charter is used for.

Historical Context

2 moments from history that rhyme with this story — and how they unfolded.

January 2021

Anchorage Digital gets the first crypto national trust charter (2021)

The OCC granted Anchorage a conditional national trust bank charter, making it the first digital asset company to receive one. The charter let it custody crypto under federal supervision rather than state licenses, and it began operating as Anchorage Digital Bank.

Then

Anchorage became the template other crypto custodians pointed to when arguing they deserved federal treatment.

Now

The charter sat mostly alone for years as banking regulators grew hostile to crypto, until a new group of applicants arrived in 2025 and 2026.

Why this matters now

Coinbase is following a path Anchorage opened five years earlier, but at a scale Anchorage never approached.

2015

New York creates the BitLicense (2015)

The New York State Department of Financial Services built a licensing regime for crypto businesses operating in the state. Circle received the first BitLicense in September 2015, and the state also chartered limited-purpose trust companies for custody.

Then

Several firms left New York rather than apply, and the licensing process drew complaints about cost and delay.

Now

New York became the de facto regulator for crypto custody in the U.S., a role the federal trust charters now begin to displace.

Why this matters now

Coinbase's custody business has answered to New York since 2018. The three-year transfer moves that authority to Washington.

Sources

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