OCC Conditionally Approves Five National Trust Bank Charter Applications

On December 12, 2025, the Office of the Comptroller of the Currency (OCC) announced that it had conditionally approved five national trust bank charter applications. Two of the applicants are de novo registrants: First National Digital Currency Bank (owned by Circle) and Ripple National Trust Bank. The other three are converting their charters from a state trust company to a national trust bank: BitGo Bank & Trust, N.A.; Fidelity Digital Assets, N.A.; andPaxos Trust Company, N.A.

Of the five applicants, three (BitGo, Fidelity, and Paxos) intend to issue a stablecoin. Circle is currently seeking a New York limited purpose trust company charter, which entity (and not First National Digital Currency Bank) will assume responsibility for issuance of Circle's USDC stablecoin. Ripple also currently uses a New York limited purpose trust charter to issue its RLUSD stablecoin. The decisions by Circle and Ripple suggest some confidence in the New York Department of Financial Services (NYDFS) as a regulator, and in the ability of NYDFS to successfully certify to a multi-agency federal committee (including the Department of the Treasury, Federal Reserve Board, and Federal Deposit Insurance Corporation) that New York's stablecoin regulatory regime is substantially similar to the federal stablecoin regulatory regime under the GENIUS Act. By contrast, Fidelity and Paxos both converted from New York state trust charters to the federal charter.

In its letters providing conditional approval to each applicant, the OCC notes that it does so with the understanding that each will maintain (relatively standard) capital levels (with no requirement the parent company enter into a capital and liquidity maintenance agreement and, consistent with the GENIUS Act placing stablecoin reserves on-balance sheet and subject to a modified capital charge). Final approval of each charter remains subject to each applicant's satisfaction of certain preopening requirements, such as acquisition of fidelity bond coverage, adoption of policies, practices, and procedures to ensure safe and sound operation, application for Federal Reserve membership, and securing other required regulatory approvals.

These conditional approvals represent the strongest signal yet of OCC's increased openness to new bank and trust bank charter applications from digital asset firms, which have increased significantly this year. We expect the recent conditional approvals will further hasten new OCC applications.

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