OCC's Recent Charter Approvals Signal Momentum for Digital-Asset Bank Charters

Key Takeaways

• The Office of the Comptroller of the Currency's (OCC) conditional approvals for digital-asset national trust bank charters reflect accelerating momentum in this area.
• National Trust Bank (NTB) charters enable fintechs to connect customers to a wide variety of digital-asset-based services.
• The growing cadre of charters granted to blockchain and digital-asset-oriented banks confirms that infrastructure, not speculation, is the key differentiator.

An Accelerated Process

On July 10, 2026, the OCC granted final approval for Circle to open First National Digital Currency Bank, N.A., which will do business as Circle National Trust. This final approval follows the OCC's conditional approval issued in December 2025 alongside similar conditional approvals for BitGo, Fidelity Digital Assets, Paxos and others. The pace and number of these approvals stand in marked contrast to prior administrations.

For the broader digital-asset industry, this approval suggests that the OCC is developing a potentially viable path for digital-asset custody through the NTB charter. Final approval remains pending for BitGo, Fidelity Digital Assets, and Paxos. Other applicants for charter grants or state-to-federal conversions also have stepped forward, including Bridge National Trust Bank, Laser Digital National Trust Bank (Nomura), and Morgan Stanley Digital Trust, among others. The industry will be watching those applications closely to assess how practical the NTB charter may be for other digital-asset firms.

In a related development on July 23, Upstart, the AI-driven lending marketplace, received conditional approval from the OCC to establish Upstart Bank, N.A. as a de novo national bank. Unlike the NTB charters, Upstart's proposed charter would be for a full-service national bank built from the ground up rather than assembled from one or more existing entities. Upstart still must satisfy OCC conditions before the charter becomes final, and its applications for FDIC deposit insurance and Federal Reserve approval to become a bank holding company remain pending. Even so, the conditional approval is notable because it suggests continued federal openness to well-developed fintech charter applications, including applications that seek to reduce reliance on third-party bank partners and bring more of the customer relationship within a single regulated institution. Upstart joins other national bank charter conditional approvals granted to NuBank (January 2026); VALT Bank (March 2026); Mercury Bank (April 2026) and Augustus National Bank (May 2026).

In a very recent postive development, the FDIC approved the application of Augustus National Bank (ANB) for deposit insurance on August 4, 2026. Such applications are evaluated by the FDIC based on a seven factor statutory framework: the financial history and condition of the institution; the adequacy of the institution's capital structure; the future earnings prospects of the institution; the general character and fitness of the management of the institution; the risk presented by the institution to the Deposit Insurance Fund; the convenience and needs of the community to be served by the institution; and whether the institutions corporate powers are consistent with the purposes of the Federal Deposit Insurance Act. While the FDIC's approval order expires if ANB is not established within 12 months, the time frame from charter application filing (December 18, 2025) to OCC conditional approval (may 8, 2026) to FDIC deposit insurance approval (August 4, 2026) speaks to a regulatory review framework not beset by delays or postponements.

The OCC also has cautioned applicants not to treat the chartering process as iterative. In June 2026 guidance on its filing-decision process, the OCC emphasized that filings must contain the information necessary for the agency to evaluate the application at the initial submission stage, and that the OCC may return a materially deficient filing before meaningful processing if the submission lacks sufficient information. The guidance states that the OCC plans to deny filings where significant supervisory, Community Reinvestment Act, or compliance concerns exist or the filer fails to provide requested information. Applicants should assume that retaining experienced regulatory counsel and, where appropriate, specialized consultants, is essential to preparing an application capable of satisfying OCC review.

Why Are NTBs Important?

It is worth reviewing why NTB charters are important and why, from an industrywide perspective, they may materially affect the digital-asset market.

First, NTB charters give fintech and crypto participants federally supervised fiduciary and custodial powers. Custody is the foundation of any digital-asset business. It assists with reconciling crypto activity; it allows direct control of reserve management for cash and Treasury reserves backing stablecoins; it can reduce the burden of navigating a complex state-by-state regulatory patchwork; and it provides regulatory credibility by operating within recognized supervisory limits. In appropriate circumstances, an NTB charter also may support institutional custody by allowing the charter recipient to operate as a qualified custodian.

Second, NTBs substantially change the competitive landscape for digital-asset and blockchain-focused enterprises. Before the recent wave of conditional approvals, Anchorage Digital was the principal crypto-focused entity operating under an NTB charter. Anchorage has emphasized its regulatory approval as a competitive advantage. Thus, one reasonably can expect that will be part of the new competitive dialogue with those who receive final approval of their trust charters. More broadly, the industry appears to be moving away from the "Wild West" characterization that was common less than five years ago and toward a stronger preference for defined regulatory boundaries, predictability, and supervisory credibility. Customers want to know their money is safe and a regulated entity is far more likely to provide a sense of security.

Third, NTB charters may allow their holders to provide services ancillary to pure custody, to the extent those services fall within the bank's fiduciary powers and approved business plan. For example, trust banks may be able to connect their client base to parts of the tokenized-asset ecosystem. Stablecoin-related services are the most prominent example today, but access to decentralized finance (DeFi), tokenized assets, and crypto exchange-based trading may become more relevant as the market matures and as regulators clarify the permissible scope of these activities.

Our Take: The Meaning in All the Activity–Infrastructure Trumps Speculation

A review of the companies that have applied for or received trust charters, converted state charters to national charters, or sought full national bank charters reveals a clear pattern: larger, more sophisticated firms are assuming new regulated responsibilities that may help them increase scale, deepen institutional capabilities, and further distinguish themselves from earlier-stage market participants. It would not be surprising for these new charter recipients to begin operating more like banks, increasing competition in that space. Nor is it surprising that at least one full national bank charter—Erebor Bank, which primarily serves Silicon Valley clients—was granted late last year. In short, the convergence of digital assets and blockchain infrastructure is accelerating. That trend is likely to continue as blockchain rails—through broader adoption of tokenized deposits and stablecoins—become increasingly important to moving funds and securities domestically and globally. Within several years, access to blockchain rails for stablecoin use, tokenized securities trading, DeFi access, and similar activities may become a practical necessity for financial institutions. Once an institution holds a trust bank charter, it also may begin exploring a full national bank charter, whether de novo, as noted above, or through acquisition, as seen in OppFi's acquisition of BNC Bank and SmartBiz's acquisition of CenTrust Bank.

However, despite the probability that the big will get bigger, there is a high likelihood that the "Crypto-As-A-Service" model will continue developing, particularly for crypto services offered to small and midsize banks. API-based connectivity and "side core" technology may make crypto-market access more affordable and operationally manageable by abstracting much of the complexity and cost banks otherwise would face. Even so, banks will need rigorous oversight, monitoring, and risk and compliance certifications, including where compliance is largely automated through smart contracts. Prudent banks should begin planning for those requirements now.

Conclusion

These digital-asset developments are another step toward a broader transformation of banking. That transformation will be visible in some areas, as early digital-asset entrants compete more directly with traditional finance institutions. In other areas, it may be less visible to end users, as fiat-based rails are gradually supplemented or replaced by blockchain-based infrastructure in ways that make the customer experience seamless and nearly frictionless.

Like many technology adoption curves, this one may continue to accelerate before it decelerates and plateaus. The next major initiative affecting banks is likely to be the broad and increasingly rapid adoption of tokenization across money market funds, Treasury securities, deposits, stocks, remittances, and real-world assets.

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Steve Gannon and Max Bonici are partners, and Paige Knight is an associate in DWT's Washington, D.C., office. For questions or more insights, please reach out to the authors or another member of our financial services team and sign up for our alerts.