OCC National Bank Charter for Crypto Firms · 2025 Update

TL;DR

The 2025 Office of the Comptroller of the Currency (OCC) update creates a clear federal pathway for crypto firms to obtain national bank or national trust bank charters. OCC Interpretive Letter 1183 (March 27 2025) reaffirms the underlying crypto-custody, stablecoin-reserve, and node-operator powers established by IL 1170 / 1172 / 1174 (2020–2021), and removes the IL 1179 (2021) requirement for advance written non-objection from supervisors — replacing it with normal-course-of-business supervisory engagement. Anchorage Digital Bank, N.A. remains the only fully-chartered national digital-asset bank (chartered January 2021); under the new framework Bitwise, Circle, Paxos, Bridge, Coinbase, Ripple, and Kraken have filed or announced charter or trust-charter applications during 2025. Custodia Bank’s Wyoming SPDI is the dominant state-chartered counter-pattern; the federal vs Wyoming charter trade-off turns on FedWire / Fed master account access (federal advantage) versus speed-to-charter and tailored crypto-native rule design (Wyoming advantage). The 2025 OCC posture restarts a charter pipeline that had been effectively closed since the original IL 1179 hold in 2021.

Wiki route

This entry sits under fintech index as the 2025 OCC update companion to OCC trust-bank charter (the underlying mechanism note). Read it with US 2025 regulatory reset for surrounding policy, with Treasury 2025 stablecoin framework for the Treasury-side coordination, and with GENIUS §501 implementation for the compliance overlay every chartered crypto bank must satisfy. For state-licensing context see US crypto licensing multi-layer.

Why this entry exists

The trust-bank charter note explained the structural arbitrage of an OCC charter for stablecoin issuers (state-MTL bypass, FedWire access, Fed master-account potential). This entry captures the 2025 charter-pipeline reality: who has applied, who has been approved, what the OCC IL 1183 clarification changed, how the federal-vs-Wyoming-SPDI trade-off plays out in practice, and what kinds of crypto firms now have a viable federal path that did not exist between 2021 and 2024. The two notes form a mechanism-then-pipeline pair.

OCC charter background · the four-letter chain

The OCC’s authority to charter national banks and national trust banks for crypto activities rests on a chain of four interpretive letters issued between July 2020 and November 2021:

Letter	Date	What it authorized
IL 1170	2020-07	National banks may provide cryptocurrency custody services for customers
IL 1172	2020-09	National banks may hold reserves backing stablecoins
IL 1174	2021-01	National banks may use independent node verification networks and stablecoins for payment activities
IL 1179	2021-11	Activities under IL 1170–1174 require prior written supervisory non-objection (effectively put new charters on hold)

IL 1179 was the operational hold that kept the charter pipeline largely frozen between 2021-Q4 and 2024-Q4. Under it, even an existing national bank wishing to engage in IL 1170 custody had to obtain advance written approval — a process that became indefinitely slow under the Biden-era OCC.

The 2025 OCC Interpretive Letter 1183 (March 27 2025):

Reaffirms IL 1170, 1172, and 1174 as continuing to state OCC’s view of the permissibility of crypto custody, stablecoin reserves, and node-operator activities.
Removes the IL 1179 prior-non-objection requirement and replaces it with normal-course supervisory engagement (the regime that applies to every other permissible national-bank activity).
Confirms that crypto-custody-and-stablecoin activities are within the business of banking under 12 U.S.C. § 24(Seventh).
Implicitly resumes the new-charter pipeline that was operationally frozen 2021-Q4 to 2024-Q4.

The combination of IL 1183 with the surrounding 2025 reset (SAB 122 rescission, FDIC and Federal Reserve guidance withdrawals, the GENIUS Act statutory anchor) converts the federal banking pathway from closed to open within a 90-day window.

Anchorage Digital Bank · the precedent case

Anchorage Digital Bank, N.A. is the only fully-chartered OCC national trust bank specifically designed around digital assets. Key facts:

Conditional approval: January 13 2021 (final months of the first Trump administration).
Charter category: National Trust Bank.
Headquartered: South Dakota.
Activities: Crypto custody, settlement, transaction services, staking, trade execution, lending, and (subject to the new framework) stablecoin issuance.
Restrictions: No deposit-taking from the public in the conventional sense; trust bank category limits.
Operational status: Active throughout 2021–2026, including expansion of services under the post-2025 framework.

Anchorage’s significance is structural rather than commercial: it demonstrated that a national bank charter for a digital-asset-native business is possible, established the operational template for federal supervision of a crypto custodian, and provided the regulatory baseline against which subsequent applicants negotiate.

Under the post-2025 framework, Anchorage’s positioning has improved further: the non-objection-removal of IL 1183 reduces friction on incremental activities, and GENIUS Act PPSI eligibility opens stablecoin issuance as a service line. Anchorage’s partnership with Tether in the announced USAT product (a US-compliant Tether-branded stablecoin) is one of the visible 2025-Q4 developments — see Tether business model for the broader Tether positioning.

Custodia Bank · the Wyoming SPDI counter-pattern

Custodia Bank (formerly Avanti Bank) operates under a Wyoming Special Purpose Depository Institution (SPDI) charter. Key facts:

SPDI charter: Granted by Wyoming Division of Banking, 2020-10.
Federal Reserve master-account application: Filed 2020; denied by Federal Reserve 2023-Q1; litigation continuing.
OCC charter approach: Not pursued; Custodia chose the state SPDI route.
Activities: Crypto custody, settlement, payments — but without Fed master-account access, which limits direct US-dollar settlement capability.

The federal-vs-Wyoming trade-off can be summarized:

Dimension	OCC national charter	Wyoming SPDI
Approval timeline	18–36 months	6–12 months historically
FedWire / FedNow access	Available	Indirect via correspondent bank
Fed master account	Available subject to Federal Reserve approval	Contested
State MTL bypass	Yes (federal supremacy)	Partial; multi-state activity still requires per-state analysis
Capital requirements	Higher	Lower
Permissible activities scope	Broad	Wyoming-defined, including 108% reserve requirement
Resolution authority	FDIC (insured deposits) + OCC	Wyoming + FDIC if insured
Political stability	Federal — changes with administration	State — more stable but smaller political base

The critical operational divider is the Federal Reserve master account. Without it, a stablecoin issuer or crypto bank cannot settle directly in central-bank money, must rely on correspondent banks, and accepts a settlement-latency penalty that materially affects products like stablecoin redemption and on-ramp / off-ramp pricing. Custodia’s denial — and the ongoing Custodia v. Federal Reserve litigation — is the single most-watched legal proceeding for the federalism question in the crypto-bank space.

Wyoming SPDI remains attractive for:

crypto-native firms prioritizing speed-to-charter over Fed access;
firms with smaller scale for which correspondent-bank settlement is acceptable;
firms positioning for future M&A by larger federally-chartered acquirers;
firms that explicitly value Wyoming legal certainty around digital-asset definitions (Wyoming has the most developed state-level digital-asset legal framework in the US).

2025 charter pipeline · who has applied

Applicant	Charter target	Status (Q1 2026)	Public rationale
Anchorage Digital Bank	Already chartered	Active; expanding services	Federal supervision baseline
Custodia Bank	Wyoming SPDI; OCC not pursued	Active under Wyoming; Federal Reserve case continuing	Speed-to-charter; Wyoming legal certainty
Bitwise	National trust bank charter (filed 2025-Q2)	Filed	Custodian-of-record for spot-crypto ETFs
Circle	National trust bank charter (filed 2025-Q3)	Filed	PPSI eligibility and FedWire access for USDC
Paxos	National trust bank charter (existing limited; expansion filed 2025-Q3)	Existing charter; expansion pending	PPSI eligibility for USDG
Bridge (Stripe subsidiary)	OCC trust-bank conditional approval (granted 2026-02)	Conditional approval received	Stablecoin platform — see [[fintech/occ-trust-bank-charter-federal-stablecoin-arbitrage
Coinbase	National trust bank charter (filed 2025-Q4)	Filed	Custody + PPSI optionality for USDC service
Ripple	National trust bank charter (filed 2025-Q3)	Filed	PPSI eligibility for RLUSD — see [[fintech/ripple-rlusd-stablecoin
Kraken	National trust bank charter (filed 2025-Q4)	Filed	Custody + future PPSI optionality
Robinhood	Considering	Under evaluation 2026-Q1	Custody + future PPSI optionality
Galaxy Digital	Considering	Under evaluation	Custody for institutional clients
Other (institutional custodians)	Multiple under evaluation

The 2025-Q3 filing surge reflects the GENIUS Act statutory clarity plus the IL 1183 procedural unlock. The OCC application backlog as of Q1 2026 is reportedly the largest single-quarter charter-application stack in the agency’s modern history for any single business category.

What an OCC national trust bank charter delivers post-2025

Under the post-2025 framework, an OCC national trust bank charter delivers:

PPSI eligibility for stablecoin issuance under GENIUS (subject to §6 supervisory standards and §501 denylist capability).
Crypto custody authority under IL 1170 / IL 1183 without per-engagement non-objection.
Stablecoin reserve management under IL 1172 / IL 1183.
Node operator authority under IL 1174 / IL 1183.
FedWire access (subject to Federal Reserve approval) for direct USD settlement.
Potential Fed master account (Federal Reserve discretion).
State MTL bypass via federal supremacy.
Federal supervisory framework — single regulator (OCC) rather than 48–50 state regulators.
Recognized institutional credibility for ETF custodianship, institutional-client onboarding, and corporate-treasury services.

The combination is the closest thing to a federal stablecoin-bank charter that exists in US law absent further GENIUS-Act-style legislation specifically creating a new charter category. For the GENIUS dual-track context see Treasury 2025 stablecoin framework.

OCC IL 1183 · what it actually clarifies

IL 1183 is a compact, three-page letter that sets out four supervisory positions:

Reaffirms the existing crypto-custody / stablecoin-reserve / node-operator authorities are within the business of banking.
Withdraws the IL 1179 prior-supervisory-non-objection requirement.
Confirms that the underlying activities do not require new express statutory authority — they fit within existing 12 U.S.C. § 24(Seventh) “business of banking” and § 27 fiduciary-trust powers.
Frames ongoing supervision through normal examination cycles rather than per-activity non-objection.

It is deliberately narrow. It does not:

create a new charter category;
authorize new activities beyond IL 1170 / 1172 / 1174;
pre-judge any particular charter applicant;
modify capital, liquidity, or governance requirements;
override Federal Reserve master-account discretion;
override FDIC insurance-eligibility analysis.

What IL 1183 changes is the operational friction that IL 1179 added to the underlying authorities. The shift is from “may engage, subject to advance non-objection” to “may engage, subject to normal-course supervisory engagement” — a meaningful re-classification because OCC’s normal-course examination cycle is routine and predictable, while IL 1179 non-objection was discretionary and effectively indefinite under the prior administration.

State-chartered trust company arbitrage

Outside the OCC national trust bank pathway and the Wyoming SPDI pathway, several state-chartered trust company options exist. These are the legacy pathway used by Coinbase Custody Trust (NYDFS limited-purpose trust company), Gemini Trust Company (NYDFS), BitGo (South Dakota and New York), and others.

State	Charter type	Strengths	Weaknesses
New York	Limited-purpose trust company (under NYDFS)	Established framework; institutional credibility	NYDFS BitLicense overhead; restrictive listing process
South Dakota	Trust company	Fast approval; tax-friendly	Smaller political base
Nevada	Trust company	Flexible	Less institutional recognition
Wyoming	SPDI (depository) or trust company	Digital-asset-native legal framework	No Federal Reserve master account
Texas	Trust company under DOB	Active 2025 framework expansion	Less established for crypto
Nebraska	Digital-asset depository institution	Bespoke 2021 framework	Limited scale

The arbitrage question is whether a state-chartered trust company plus a federal-regulator partnership can deliver most of what an OCC charter delivers without the OCC approval timeline. The answer historically was “yes for custody, no for FedWire / Fed master account.” The 2025 reset narrows but does not eliminate the gap: federal-banking-relationships are easier for state-chartered crypto trust companies (post-SAB 122, post-FDIC guidance withdrawal, post-Federal Reserve SR 22-6 rescission), but direct Federal Reserve master-account access continues to favor the OCC national charter route.

For the broader state-licensing context see US crypto licensing multi-layer and five-pole matrix for the international comparison.

How the OCC pathway interacts with the broader 2025 reset

The OCC pathway is the banking-side of the reset, complementary to:

SEC-side reset — enforcement rollback and the Atkins/Peirce posture (CFTC vs SEC and Hester Peirce pivot).
Treasury-side framework — PWG-DAM recommendations, reserve composition, MRA work (Treasury 2025 framework).
Statutory anchor — GENIUS Act PPSI charter, §501 denylist mandate (GENIUS §501 and §501 implementation).
Federal Reserve posture — SR 22-6 rescission, openness on master accounts subject to standard analysis.
FDIC posture — FIL withdrawals, deposit-insurance analysis for stablecoin reserves.

Without all five legs, the OCC pathway would have re-opened formally but operated narrowly. With all five legs, OCC charters become a strategic asset for crypto firms operating at scale, and the Bridge / Stripe acquisition pattern (see regulatory window M&A) becomes a repeatable template.

Market consequences

The OCC pathway reopening produced a measurable market response:

Surface	Pre-2025	Post-2025
Active OCC national charters for crypto firms	1 (Anchorage)	1 active + 1 conditional (Bridge) + 6–10 pending
State-only crypto trust companies	~12 across NYDFS, SD, NV, WY, NE	Stable, with several seeking federal upgrade
Wyoming SPDI charters	2 (Custodia, Kraken Bank)	Stable; no new approvals while Custodia litigation pends
Federal Reserve master-account approvals for digital-asset banks	1 (Anchorage)	1 active; multiple applications pending
State-MTL exposure for federally-chartered crypto banks	Theoretical bypass; not tested at scale	Active bypass realized in practice
Strategic M&A around charter holders	Limited	Active (Stripe/Bridge as template)

For the M&A pattern see regulatory window M&A; for the network-neutrality investment pattern that runs in parallel see Wall Street network neutrality.

Sources

OCC interpretive letters and actions: https://occ.treas.gov/topics/charters-and-licensing/interpretations-and-actions/
OCC news releases: https://occ.treas.gov/news-issuances/news-releases
OCC charters database: https://occ.treas.gov/topics/charters-and-licensing/charters/index-charters.html
Treasury digital assets policy: https://home.treasury.gov/policy-issues/financial-markets-financial-institutions-and-fiscal-service/digital-assets
Federal Reserve press releases: https://www.federalreserve.gov/newsevents/pressreleases.htm
Wyoming Banking Division SPDI page: https://wyomingbankingdivision.wyo.gov/banks-trust-companies/special-purpose-depository-institutions
Federal Register filings: https://www.federalregister.gov/
Anchorage Digital Bank OCC conditional approval letter (January 2021)
OCC Interpretive Letter 1170 (July 2020), IL 1172 (September 2020), IL 1174 (January 2021), IL 1179 (November 2021), IL 1183 (March 2025)
GENIUS Act statutory text (Public Law as enacted July 2025)