The OCC crypto bank charter queue now contains 13 pending digital asset licensing applications, Comptroller Jonathan Gould confirmed on 11 August, as the regulator signalled it intends to keep that route open rather than impose a blanket exclusion on new entrants.
Gould framed the push in institutional terms. OCC-supervised institutions collectively hold more than $17 trillion in assets, administer more than $85 trillion under their control, and account for approximately 67 percent of all US banking activity, according to the OCC’s own figures. Opening that system to digital asset firms, Gould said, means ‘America and the OCC are once again open for business.’
Inside the OCC Crypto Bank Charter Pipeline
The 13 pending applications span a range of structures and geographies. Named applicants include Payward National Trust Company and Agora National Trust Bank (both New York), Revolut Bank US N.A. (Stamford, CT), EDX Trust N.A. (Chicago), World Liberty Trust Company, PAYO Digital Bank, and Dakota National Trust Bank, whose 28 July filing is the most recent on the list.
Beyond those named in earlier reports, the OCC’s digital assets licensing list also shows Catena Trust Bank N.A. (received 18 May 2026), OpenReserve Bank N.A. (received 13 April 2026), Lorum National Trust Bank N.A. (received 31 March 2026), Bastion Platforms National Trust Company (received 30 March 2026), The First National Bank of Cooper (received 8 July 2026), and CBW Bank (received 26 June 2026).
The pipeline sits downstream of a productive December 2025 approval round, though the December decisions covered two distinct tracks. The OCC’s December 2025 conditional approvals separated de novo national trust bank charter applicants (Circle’s First National Digital Currency Bank and Ripple National Trust Bank) from state trust company conversion applicants (BitGo Bank & Trust N.A., Fidelity Digital Assets N.A., and Paxos Trust Company N.A.). Circle’s First National Digital Currency Bank became effective 10 July. Coinbase received preliminary conditional approval in April.
Selectivity Is Still Part of the Process
The Wise National Trust denial on 21 July is the clearest evidence the process is not a rubber stamp. The OCC’s Corporate Decision 1381 states the application ‘presents significant supervisory and compliance concerns and approval of the application would be inconsistent with the policies set forth in 12 CFR 5.20.’ The denial does not bar Wise from reapplying.
The OCC’s May 2025 guidance on crypto-asset custody and execution services set the conduct standard applicants must meet: custody activities, including via a sub-custodian, must be conducted in a safe and sound manner and in compliance with applicable law. That standard runs through any conditional approval and shapes what regulators examine before granting final authorisation.
On the enforcement side, the OCC terminated a consent order against Anchorage Digital Bank, National Association, effective 18 August 2025. The termination order concluded that the safety and soundness of Anchorage and its compliance with laws and regulations no longer required the order, which had originally been dated 21 April 2022. That termination suggests the OCC is willing to work through supervisory deficiencies rather than simply revoke a charter.
Political resistance has not faded. Senator Elizabeth Warren has pressed Gould to explain the legal basis for approving digital asset applicants under the National Bank Act. The Bank Policy Institute’s June comment on Payward asked the OCC to examine capital and liquidity support, affiliate transactions, resolution planning, and whether proposed activities fall within national trust bank powers. The OCC’s April chartering rule clarified that its authority was neither expanded nor contracted by replacing references to ‘fiduciary activities’ with ‘operations of a trust company and activities related thereto.’
The FDIC’s parallel reform, announced 10 August, creates a two-phase review for deposit insurance applications received after 15 August: phase one targets contingent authorisation within 120 days; phase two allows up to 12 months to satisfy final conditions. Most national trust bank charter applicants in the crypto pipeline do not seek FDIC-insured deposits, so the new process applies selectively. Erebor Bank N.A., which received preliminary conditional OCC approval on 15 October 2025, obtained FDIC deposit insurance approval on 16 December 2025, demonstrating that the full OCC-plus-FDIC path exists for firms that need insured deposits.
The next concrete milestones are further OCC decisions on the 13 pending applications and any movement on the conditional approvals already granted. A formal legal challenge from banking groups to any individual approval would test whether the OCC’s current chartering stance survives judicial scrutiny.
