Coinbase National Trust Charter Receives Final OCC Approval

Coinbase announced on November 9, 2026, that the Office of the Comptroller of the Currency granted final approval for Coinbase National Trust Company, a New York-based national trust bank charter effective November 6, 2026. The uninsured charter, Control No. 2025-Charter-343449 and proposed Charter #25390, allows the wholly owned subsidiary of Coinbase Global to provide fiduciary digital-asset custody services primarily to institutional clients under a single federal framework.

Coinbase National Trust Charter Details and Conditions

The charter authorizes expanded institutional crypto custody operations that build on Coinbase Custody Trust Company, the limited-purpose trust entity licensed by the New York Department of Financial Services since 2018. It does not permit retail deposits, lending activities, or stablecoin issuance under the current plan. The trust company may act as a finder for affiliate services such as staking and Prime offerings but will not deliver those services directly.

Key conditions apply for the first three years of operation. Coinbase National Trust Company must maintain at least $60 million in Tier 1 capital. It must also hold liquid assets covering the greater of 50 percent of that capital or $30 million, plus an additional 180 days of operating expenses in eligible liquid assets. Any significant changes to the business plan require 60 days prior notice and OCC non-objection. The entity must comply with the GENIUS Act requirements throughout this period.

Migration of custody assets from the existing New York entity to the new federal charter is scheduled over a three-year de novo period. This phased transition allows time to align operations, risk management, and client onboarding with federal standards while maintaining continuity for institutional customers.

Background on OCC Approvals for Crypto Firms

The application was filed on October 3, 2025, received preliminary conditional approval on April 2, 2026, under OCC Corporate Decision #1370, and reached final approval 218 days later. Coinbase joins Circle, which received final approval around July 2026, and Ripple, which obtained its charter in October 2026, as crypto companies operating under national trust charters.

Executives including Vice Chairman Ryan VanGrack and Rick Schonberg stated that the federal charter provides clear and consistent uniformity across jurisdictions. They noted that it advances integration of digital assets into U.S. financial infrastructure by replacing multiple state-level licenses with one federal oversight structure.

Banking industry groups such as the Independent Community Bankers of America continue to challenge the OCC framework in court. These legal proceedings address the broader question of whether the OCC should issue national trust charters to cryptocurrency-focused firms, though the challenges do not target Coinbase specifically at this stage.

Next Steps After Coinbase National Trust Charter Approval

Operational launch and the phased custody migration will begin immediately under the new charter. Any future expansions, such as payments or stablecoin-related services, would require separate OCC notice and non-objection before implementation.

The approval establishes a federal regulatory baseline for Coinbase institutional custody activities. Clients can expect continued service through the existing New York entity during the transition, with documentation updates provided as accounts move to Coinbase National Trust Company over the coming three years.