Coinbase announced on November 9 that its subsidiary, Coinbase National Trust Company, has received final approval from the Office of the Comptroller of the Currency (OCC) to operate as a national trust bank in the U.S. Effective November 6, the charter enables the New York-based entity to provide digital asset custody services to institutional clients under federal banking supervision.
The decision follows Coinbase’s conditional approval in April 2026, paving the way for the company to transition its institutional custody business from state-level frameworks to the OCC. The charter does not turn Coinbase into a commercial bank, as the entity is not permitted to accept traditional retail deposits or engage in commercial lending. Client assets are also not FDIC-insured.
Introducing Coinbase National Trust Company, our federally chartered trust company.
OCC approved. pic.twitter.com/jhqyDdFyLk
— Coinbase 🛡️ (@coinbase) November 9, 2026
The Scope of Coinbase’s New Charter
The charter permits Coinbase National Trust Company to provide digital asset custody services with fiduciary obligations, requiring the company to manage assets solely in the interest of its clients. The entity may also receive, hold, and transfer fiat currency or digital assets directly related to custody accounts.
Custodied fiat funds will be held in “for benefit of” (FBO) accounts at third-party banks and cannot be used by the trust bank to extend credit. Coinbase National Trust Company may refer clients to staking, Prime Trading, and Prime Financing products provided by Coinbase affiliates. The trust bank will act strictly in a referral capacity rather than directly operating these services.
In its initial approval decision, the OCC noted that Coinbase National Trust Company did not propose issuing stablecoins. As such, the current charter does not automatically allow the entity to issue stablecoins or expand into payment services outside the approved plan. Any material changes to operations or risk limits must be submitted in advance and may only be implemented after OCC confirmation of no objection.
Institutional Custody Moves to a Federal Framework
Coinbase will transition its institutional custody operations to Coinbase National Trust Company during its first three years of operation. This segment is currently operated through Coinbase Custody Trust Company, a limited-purpose trust company regulated by the New York State Department of Financial Services.
Following the transition, custody operations will fall under OCC supervision instead of continuing to operate primarily under a state-level charter. Coinbase primarily targets its custody services at investment funds, ETF issuers, banks, and asset managers, clients with high requirements for asset safekeeping, auditing, and risk control.
Coinbase recorded $376.6 billion in Assets on Platform at the end of Q3 2026, representing approximately 12.5% of total crypto market capitalization, according to company disclosures. This metric includes assets across custody services and other platform products, not just assets expected to transfer to the trust bank.
Subscription and services revenue reached $570.2 million in Q3, accounting for 49% of net revenue, up from 41% a year earlier. In absolute terms, revenue for this segment fell 20% year-over-year. The Q3 report filed with the SEC does not break out custody revenue separately, and Coinbase has not provided financial contribution estimates for the new charter.
Capital and Compliance Requirements Remain
During its first three years of operation, Coinbase National Trust Company must maintain a minimum of $60 million in Tier 1 capital. The trust bank must also hold qualifying liquid assets equal to the greater of 50% of Tier 1 capital or $30 million.
In addition to liquidity supporting capital requirements, Coinbase National Trust Company must maintain sufficient assets to cover at least 180 days of operating expenses under distressed or wind-down scenarios.
The OCC requires the trust bank to engage independent auditors, with annual audits expected for at least the first three years. The company must also implement an information security program alongside compliance measures for the Bank Secrecy Act, anti-money laundering regulations, and Office of Foreign Assets Control sanctions. System architecture, technology risk assessments, and related management plans must be reviewed and receive no-objection confirmation from the OCC prior to going live.
Banking Groups Challenge the OCC’s Authority
Coinbase joins a group of digital asset companies that have integrated their operations into the U.S. national trust bank system. Ripple National Trust Bank became effective on October 26, less than two weeks before Coinbase’s charter was finalized.
The Independent Community Bankers of America (ICBA) filed a lawsuit against the OCC in Washington federal court on October 2. The lawsuit challenges national trust bank regulations issued in March 2026 and Interpretive Letter 1176. The ICBA contends that the OCC exceeded its authority under the National Bank Act by permitting trust banks to conduct substantial activities outside traditional fiduciary scope.
Following Coinbase’s final approval, the ICBA separately reiterated its opposition to the decision. The organization representing community banks argued that a national trust charter could create the impression of protection equivalent to an insured bank, even though digital assets at these entities are not FDIC-insured and trust banks are not subject to all requirements applied to insured depository institutions.
In its decision approving Coinbase, the OCC affirmed that the National Bank Act authorizes the agency to grant charters to banks limiting their operations to trust company activities and related services. The ICBA lawsuit does not automatically suspend the charter, allowing Coinbase National Trust Company to operate under OCC supervision while the dispute remains under review.
