Coinbase's Federal Trust Charter Takes Effect, Enabling Three-Year Custody Migration
Key Takeaways
- •The OCC confirmed that Coinbase National Trust Company's federal charter became effective on November 6, 2026, after the regulator granted conditional approval on April 2, 2026.
- •Coinbase plans to move its entire existing custody business from its New York state-chartered trust to the new federal trust within a three-year initial operating period, with both charters operating during the phased transfer.
- •The OCC requires the trust to hold a minimum of $60 million in Tier 1 capital, maintain liquid reserves covering 180 days of operating expenses including at least $30 million, and complete quarterly capital and liquidity assessments throughout the initial period.
- •The charter restricts the trust to fiduciary digital asset custody and bars it from deposit-taking, commercial lending, staking, trading, financing, and stablecoin issuance, though it may refer custody customers to services from Coinbase affiliates.
- •Coinbase's October 2025 application reported $245.7 billion in assets under custody as of June 30, 2025, roughly 7% of the cryptocurrency market's value at the time, but this historical company-wide figure does not represent confirmed balances transferring into the new trust.
Coinbase National Trust Company's federal charter became effective on November 6, 2026, according to the Office of the Comptroller of the Currency (OCC), opening a three-year transition period for the exchange's institutional custody business. The effective date also shifts custody oversight for that business from state-level regulation to federal banking supervision as the migration proceeds.
In a November 9 announcement, Coinbase confirmed final approval for Coinbase National Trust Company. The decision follows the regulator's earlier conditional approval, granted on April 2, 2026.
OCC Filing Details a Three-Year Custody Migration
An OCC decision document outlines a phased transfer from Coinbase Custody Trust Company, the firm's existing custody entity, to the new federal trust. Coinbase plans to migrate its entire existing custody business during the trust's three-year initial operating period. Because the transfer is phased, the custody business spans two charters until it completes: the existing state trust and the new federal one.
The existing company holds a New York trust charter and operates under state regulatory supervision. Coinbase said the new structure builds upon its relationship with New York's financial regulator.
Coinbase's October 2025 application reported $245.7 billion in assets under custody as of June 30, 2025, a figure representing approximately 7% of the cryptocurrency market's value at that time. That number is a historical company-wide measure, not a confirmed balance transferring into the newly chartered trust.
The application identified Prime Vault and Prime Custody among the custody services intended to run under the federal charter. It also outlined arrangements enabling customers to access services provided by other Coinbase entities. The OCC described permissible transactions as receiving, holding, and transferring assets within custody accounts. Fiat custody balances will sit in accounts at third-party banks.
Federal Charter Brings Specific Operating Restrictions
The OCC authorized fiduciary digital asset custody under federal banking supervision, and its decision states that the trust's custody services must follow applicable fiduciary duties and standards — obligations that require the custodian to act in the interests of the customers whose assets it holds.
The regulator set a $60 million minimum in Tier 1 capital for the trust's first three years. It also required eligible liquid assets and separate reserves covering 180 days of operating expenses. The liquidity requirement includes at least $30 million, potentially more depending on the bank's capital. That three-year capital floor spans the same initial operating period in which Coinbase plans to complete the custody migration.
The OCC additionally requires quarterly capital and liquidity assessments during the bank's initial operating period, creating recurring regulatory checkpoints across the transition. Material business-plan changes require 60 days' advance notice and written regulatory clearance, subject to specified exceptions. The trust cannot function as a conventional deposit-taking or commercial lending bank, a scope that separates it from a full-service national bank.
The OCC specified that Coinbase National Trust Company will not directly provide staking, trading, or financing. Instead, the entity may connect custody customers with eligible services offered through Coinbase affiliates, keeping those activities outside the trust's federally authorized custody activities.
The regulator's April decision also stated that the trust application did not propose stablecoin issuance. Consequently, the charter should not be presented as approval for that separate activity.
As CoinCentral previously reported, April's initial approval depended on further regulatory steps. The latest OCC status confirms the effective charter, but does not establish any completed asset transfers. With the transfer phased across the initial operating period, confirmed custody-transfer milestones would surface through future Coinbase or OCC disclosures rather than the charter's effectiveness itself.
