OCC Reopens National Bank Charter Path for Crypto Firms Under Gould
Key Takeaways
- •The OCC has received 40 new bank applications over the past 18 months, with 13 digital asset charter applications currently pending as of the latest reporting.
- •Several major crypto firms including Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos received conditional approvals in December 2025, while Circle's First National Digital Currency Bank charter became effective on July 10.
- •The OCC has accelerated its review process, with many complete applications now receiving decisions within 120 days.
- •Senator Elizabeth Warren and banking industry groups have challenged whether certain OCC approvals exceed the agency's authority under the National Bank Act and questioned whether the national trust charter framework adequately addresses risks associated with digital asset firms.
- •The FDIC announced a revised two-phase deposit insurance review system on August 10, targeting contingent authorization within 120 days for applications received after August 15.

The U.S. Office of the Comptroller of the Currency (OCC) is reopening a pathway for digital asset firms to obtain national bank charters, with Comptroller Jonathan V. Gould stating on Aug. 11 that legally permissible crypto activities should have access to the federal banking system.
The OCC has received 40 new bank applications over the past 18 months, reflecting a broader effort by the agency to encourage new bank formation after a prolonged decline. According to Gould, the OCC aims to reverse a trend that saw fewer than four charter applications filed annually between 2011 and 2014. For digital asset firms, a national bank charter offers a route to operate custody, settlement, and payment functions under direct federal supervision rather than relying on state-level licenses or third-party banking partners—a structural shift for an industry that has long faced uneven access to the traditional financial system.
The regulator has also accelerated its review timelines. Many complete applications are now receiving decisions within 120 days, the OCC said.
13 Digital Asset Charter Applications Pending
The OCC's digital asset licensing list currently shows 13 pending applications. These include Payward National Trust Company, World Liberty Trust Company, Revolut Bank US, PAYO Digital Bank, EDX Trust, Agora National Trust Bank, and Dakota National Trust Bank. Dakota's July 28 filing is the most recent application on the list.
Several major crypto firms have already advanced through the process. Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos received conditional approvals in December 2025. Coinbase obtained preliminary conditional approval in April, and Circle's First National Digital Currency Bank charter became effective on July 10.
Not every applicant succeeds, however. The OCC denied Wise National Trust's application on July 21.
Scrutiny From Lawmakers and Banking Groups
The expanded charter activity has drawn pushback. Banking industry groups have questioned the scope of national trust charters in covering cryptocurrency operations. Senator Elizabeth Warren has separately challenged whether certain OCC approvals exceed the authority granted under the National Bank Act.
The Bank Policy Institute has also weighed in, asking the OCC to scrutinize Payward's capital levels, liquidity, affiliate transactions, and resolution planning. The pushback reflects a broader debate over whether the national trust charter framework—originally designed for traditional fiduciary and custody services—adequately addresses the risk profiles of firms holding digital assets at scale.
FDIC Introduces New Deposit Insurance Review
The regulatory landscape is shifting on other fronts as well. On Aug. 10, the Federal Deposit Insurance Corporation (FDIC) announced a revised deposit insurance review system for applications received after Aug. 15.
Under the new framework, phase one targets contingent authorization within 120 days of application receipt. Phase two can extend up to 12 months while applicants work through requirements needed for final approval. Many crypto firms pursuing national trust charters, however, do not seek FDIC-insured deposits.
OCC Updates Chartering Terminology
Separately, the OCC revised its chartering terminology effective April 1. The updated rule replaced references to "fiduciary activities" with "operations of a trust company." The agency emphasized that the change neither expands nor reduces its chartering authority.
Gould said the OCC will continue encouraging the formation of new banks and supporting legally permitted digital asset businesses seeking federal charters.