Block, the payments company founded by Jack Dorsey, filed on September 8, 2026 an application with the OCC for a national trust bank charter to launch Builders Bank & Trust, N.A., an entity entirely dedicated to bitcoin custody and stablecoin settlement.
🔑 Key takeaways
- Builders Bank & Trust, N.A. would be an uninsured, branchless national trust, headquartered in Sioux Falls, South Dakota.
- Permitted activities: bitcoin custody, riskless-principal trade execution, and stablecoin settlement — no deposits, no loans.
- Block processed roughly $10.7 billion in bitcoin transaction volume in 2025, with ~2 million monthly crypto users on Cash App in Q2 2025.
- The OCC has already granted conditional approvals to Circle, Ripple, BitGo, Fidelity Digital Assets, Paxos, Crypto.com and Bridge (Stripe).
- Senator Elizabeth Warren challenges the legality of crypto trust charters for entities without traditional fiduciary activity.
Builders Bank: a trust built around bitcoin
The application filed with the Office of the Comptroller of the Currency (OCC) seeks to create Builders Bank & Trust, N.A., a deliberately minimalist vehicle: uninsured, branchless, and barred from taking deposits or making loans. Its core mandate covers custody of bitcoin and other digital assets, execution of buy and sell orders on a riskless-principal basis, and stablecoin settlement.
Headquarters would be in Sioux Falls, South Dakota, a state long friendly to specialized financial institutions. None of the five proposed directors, however, resides within the state, prompting Block to request a waiver of the OCC rule requiring one director to live within 100 miles of the bank. The chair and CEO role would go to Lee Woolley, Block’s head of digital asset strategy and a former Northern Trust and BNY Mellon executive — classic banking credentials for an otherwise unconventional business. Jack Dorsey appears in the filing only as co-founder, without any organizer, director or executive role. The business plan and capital figures were filed as confidential exhibits; the bank cannot open until formal OCC approval.
For law firm Davis Wright Tremaine, custody remains « the foundation of any digital asset enterprise. » By moving from a patchwork of 50+ state money transmitter and virtual currency licenses to a single federal charter, Block aims to unify its supervision and boost institutional credibility.
Cash App, Bitkey and Block’s bitcoin machine
Block is no newcomer. The group has run digital asset services for roughly eight years, primarily through Cash App. According to the filing, bitcoin transaction volume processed by Block reached $10.7 billion in 2025, while about 2 million monthly crypto users transacted on Cash App in Q2 2025. In total, more than 24 million active users have bought bitcoin through the app.
Block’s bitcoin stack spans several layers: payments via the Lightning Network, self-custody with hardware wallet Bitkey, open-source mining hardware (Proto), and the rollout of native bitcoin payments to millions of Square merchants. For Lee Woolley, « the combination of Block’s digital asset experience and Square Financial Services positions Builders Bank well to support Block’s broader vision of economic empowerment. »
Key metrics of the Block ecosystem
| Metric | Value | Period |
|---|---|---|
| Bitcoin transaction volume processed by Block | $10.7 billion | Year 2025 |
| Monthly crypto users on Cash App | ~2 million | Q2 2025 |
| Cumulative active users who bought bitcoin | 24 million+ | All-time |
| State money transmitter / virtual currency licenses | 50+ | Currently active |
| Networks supporting USDC in Cash App | Solana, Ethereum, Polygon, Arbitrum | 2025-2026 |
Stablecoins: a strategic pillar despite Dorsey
The filing makes explicit room for stablecoins, which is striking for a company whose founder has publicly expressed reservations. Jack Dorsey has repeatedly said he does not like stablecoins and prefers to build « on bitcoin. » Yet bitcoin product lead Miles Suter embraces the angle, calling stablecoins « upgraded fiat » and defending a funnel strategy.
« As stablecoins continue to gain global adoption, we see an opportunity to bring millions more Cash App customers onto open financial rails. Once they’re on those rails, they’re one step from bitcoin. »
Miles Suter, Head of Bitcoin Product at Block
Cash App now supports USDC on Solana, Ethereum, Polygon and Arbitrum, with free sends and receipts and automatic conversion to USD. For Aishwary Gupta of Polygon, « this is when stablecoins stop being a crypto product and become mainstream payment infrastructure. » Tony DeSanctis (Cornerstone Advisors) sees a payment diversification logic; Richard Crone adds a flywheel effect — accumulated refunded balances attract more monthly active users, who can then be exposed to bitcoin.
A wave of crypto charters at the OCC
Block enters an established pipeline. Last December, the OCC granted conditional approvals to five crypto trust charters: Circle, Ripple, BitGo, Fidelity Digital Assets and Paxos. In February, Crypto.com and Bridge (a Stripe subsidiary) received the same green light. Coinbase secured preliminary approval in April 2026. Applications from Morgan Stanley, Payoneer, Zerohash, Kraken (Payward) and World Liberty Financial remain pending. The OCC rejected Wise National Trust’s application in July.
The regulator also broadened its charter definition in April to cover « the operations of a trust company and activities incidental thereto, » an expansion that explicitly captures crypto activity. According to OCC data, out of 40 new charter applications received over the last 18 months, 23 (57.5%) involve some form of digital asset activity, with 21 approved and 2 denied. Comptroller Jonathan Gould called the trend an « eightfold increase versus the previous four years. »
An evolving regulatory framework
The GENIUS Act, signed on July 18, 2025, now structures the stablecoin segment. In February, the OCC proposed implementing rules covering reserves, redemption, custody, risk management and issuer requirements. Meanwhile, the Bank for International Settlements (BIS) warned in August that broader use of dollar-denominated stablecoins could fuel « digital dollarisation » and weaken monetary sovereignty in some countries. The IMF estimates that tokenization could accelerate cross-border capital flows and currency substitution.
Warren’s political pushback
On May 18, Senator Elizabeth Warren (D-MA) wrote to Comptroller Jonathan Gould contesting the legality of crypto charters. She argued the OCC lacks the authority to grant a trust charter to entities that do not perform traditional fiduciary work.
« These firms are effectively crypto banks that want to escape the fundamental safeguards and obligations that come with bank status. »
Elizabeth Warren, U.S. Senator (D-Massachusetts)
The critique frames the core debate: should crypto custody be treated as a classic fiduciary activity, or governed by a bespoke regime? The OCC’s answer will shape how crypto companies can operate inside the U.S. banking system.
Conclusion: a real-world test for crypto custody
Block’s application is a textbook case. It bundles bitcoin custody, trade execution and stablecoin settlement inside a single federal entity, while remaining outside FDIC insurance and the retail banking perimeter. If Builders Bank secures its charter, Block can consolidate its activities under one framework, reduce reliance on state-by-state licensing, and offer institutional-grade custody to its clients — including the fintech businesses that orbit Cash App and Square.
Conversely, a rejection or extended freeze could push Block to scale up its offshore arm or to dilute Cash App’s stablecoin value proposition. More broadly, the OCC’s decision will draw the line between traditional fiduciary banking and regulated crypto infrastructure, at a time when 57.5% of new charter filings already carry a digital asset component.
Sources
- Decrypt — Jack Dorsey’s Block Applies for Bank Charter to Custody Bitcoin
- Bloomberg — Dorsey’s Block Joins Crypto Bank Race With National Trust Bid
- Yahoo Finance — Block Applies for OCC Charter to Launch Builders Bank
- American Banker — Jack Dorsey’s Block Adds Support for Stablecoins
- Block — Bitcoin vision and ecosystem
This article is for informational and educational purposes only. It does not constitute investment advice. Do your own research (DYOR) before making any decision.
