OCC conditionally approved five digital-asset trust bank charters

On December 12, 2025, the Office of the Comptroller of the Currency conditionally approved five national trust bank charter applications tied to major digital-asset businesses. The action covered two proposed new banks—First National Digital Currency Bank, affiliated with Circle, and Ripple National Trust Bank—and conversions for BitGo, Fidelity Digital Assets and Paxos from state trust-company structures to national trust banks.

The batch was consequential because it moved stablecoin reserve administration, digital-asset custody and related infrastructure closer to a single federal supervisory perimeter. The OCC said the applicants, if they satisfied its conditions, would join roughly 60 national trust banks already under the agency’s supervision. It did not grant a general crypto license, approve any token as an investment, or turn the applicants into ordinary deposit-taking banks.

What the OCC approved

The agency described all five decisions as conditional and said it reviewed each application on its own merits under the standards used for other charter applications. Circle and Ripple received preliminary approval to establish new national trust banks. BitGo, Fidelity Digital Assets and Paxos received approval for conversions, subject to the conditions in their individual decision letters.

The distinction between a national trust bank and a full-service commercial bank was central on December 12. The proposed Circle and Ripple institutions were not insured depository institutions. They could not present their products as FDIC-insured deposits, and the charters did not authorize consumer checking or savings accounts. Their permitted activities were narrower and connected to trust powers, custody, fiduciary services and related digital-asset operations.

Circle said First National Digital Currency Bank, once fully approved, would oversee management of the USDC reserve on behalf of Circle’s U.S. issuer and could provide fiduciary digital-asset custody. The OCC’s decision letter was even more specific: the bank itself would not issue the stablecoin; it would provide collateral-trustee services for USDC holders and custody for affiliates. That separation matters because federal supervision of a reserve or custodian is not the same thing as federal deposit insurance for a stablecoin.

Ripple similarly presented its proposed bank as a federally supervised institution that would manage reserves connected to RLUSD and support institutional services. The OCC’s letter again said the bank would not itself be the stablecoin issuer. The difference between an affiliated issuer and a federally chartered trustee was easy to blur in promotional descriptions, but it was material to the legal scope of the approval.

Why the batch mattered

The approvals arrived after the GENIUS Act became law in July 2025, giving payment stablecoins a federal statutory framework while leaving regulators to implement its requirements. The OCC’s decisions showed how crypto-focused firms could seek bank supervision for custody, reserve and settlement functions rather than operate only through state-by-state trust or money-transmission regimes.

For institutions, a national charter offered a more uniform supervisory relationship and potential nationwide operation where federal law preempted duplicative state requirements. For the market, the signal was structural rather than directional: large stablecoin and custody providers were being evaluated inside the federal banking system. The approvals did not establish demand, revenue, solvency, token safety or a future price for USDC, RLUSD, XRP, bitcoin or any other digital asset.

The action was also contested. Banking groups argued that limited-purpose trust charters could permit bank-like activities without the obligations attached to insured commercial banks. The OCC answered that it had longstanding authority and experience supervising uninsured national trust banks, while its decision letters imposed institution-specific capital, governance, compliance and risk-management conditions.

What remained unresolved on December 12

Conditional approval was a milestone, not the end of the chartering process. Each applicant still had to satisfy the OCC’s conditions, and the permissible business of each bank remained bounded by its approved plan and applicable law. On December 12, 2025, the responsible conclusion was therefore narrow: the federal banking perimeter had opened to five significant digital-asset trust-bank applications, but final operation and the practical effects of those charters still required separate verification.