OCC conditionally approves Coinbase national trust bank

The Office of the Comptroller of the Currency granted preliminary conditional approval on April 2, 2026 for Coinbase Global to establish Coinbase National Trust Company in New York. The decision created a path for Coinbase’s institutional digital-asset custody operation to become a federally supervised national trust bank, but it did not authorize the proposed bank to begin business.

The distinction was central to the event. The OCC retained authority to modify, suspend or rescind the approval before granting a final charter. Coinbase still had to organize the entity, satisfy the regulator’s preopening requirements and pass a preopening examination.

What the OCC approved

According to Corporate Decision No. 1370, the proposed bank would be a wholly owned Coinbase subsidiary providing digital-asset custody in a fiduciary capacity, primarily for institutional clients. Custody customers could accept, hold and transfer custodied fiat currency and digital assets through their accounts.

The OCC also permitted the bank to facilitate customer access to affiliate services involving staking, prime trading and prime financing. The bank itself would not provide those underlying services; it would act as a finder connecting custody customers to Coinbase affiliates. Those services would be limited to customers’ custodied assets.

Coinbase planned to transfer the entirety of the custody business conducted by its New York-chartered Coinbase Custody Trust Company to the national trust bank during a three-year de novo period. Coinbase said separately that its exchange business, BitLicense and existing state oversight would continue. It also said the proposed trust company would not take retail deposits or engage in fractional-reserve banking.

Conditions before opening

The approval imposed substantive financial and supervisory conditions. The proposed bank had to maintain at least $60 million of tier 1 capital. The greater of 50% of that capital or $30 million had to remain in eligible liquid assets, and the bank separately had to hold eligible liquid assets covering 180 days of operating expenses. Those requirements would apply during its first three years of operation.

Coinbase also needed the OCC’s written non-objection before making a significant change to the approved business plan. The regulator required controls covering anti-money-laundering compliance, sanctions, customer-information security and information-systems risk. Capital had to be raised within 12 months, and the bank had to open within 18 months of the preliminary approval or the approval would expire absent an extension under extenuating circumstances.

The OCC said it had received five public comments: two from banking trade groups and three from community groups. Objections included challenges to the agency’s chartering authority, the disclosure and comment process, competitive effects and the treatment of uninsured national trust banks. The OCC concluded that Coinbase’s proposed activities were permissible trust-company operations and that the policy objections did not justify denying the application.

Why the decision mattered

The immediate institutional significance was regulatory structure rather than a new retail banking product. Coinbase’s existing custody platform operated through a state trust company; the proposed charter offered one federal supervisory framework for the custody business and its approved related activities. That could reduce state-by-state complexity for an operation serving institutional clients, although the event-day record did not establish how much business would move or when final authorization would arrive.

The decision also placed enforceable boundaries around the expansion. The proposed entity was required to remain a trust company and could not become a bank as defined by the Bank Holding Company Act. It therefore did not give Coinbase a general commercial-banking license, deposit insurance or immediate permission to open.

As of April 2, 2026, the verified development was a preliminary regulatory approval with detailed conditions—not a completed charter, an operating bank or evidence of a measurable change in cryptocurrency prices or custody volumes.