Coinbase Wins Full U.S. Federal Trust Charter From the OCC

On November 9, 2026, the Office of the Comptroller of the Currency (OCC) converted Coinbase’s conditional approval into a full national trust bank charter. The largest U.S. crypto exchange is now inside the federal banking system, though it is not becoming a commercial bank.

A thirteen-month process with a status to clarify

The application was filed on October 3, 2025 with the OCC to create Coinbase National Trust Company, a de novo national trust bank that is uninsured, based in New York and wholly owned by Coinbase Global. On April 2, 2026, the OCC granted conditional approval, sometimes described as provisional. Coinbase’s chief legal officer, Paul Grewal, said at the time that the business would not operate under the charter until final approval was obtained.

The available sources do not fully agree on this point. Bloomberg, Bank Dive and BlockEden, in their April 2026 coverage, describe an application or a conditional approval, while the November 9 announcement establishes the move to full status. A BlockEden headline refers to a “federal bank charter”, but the article itself makes clear the authorization was still conditional on that date. The chronology used here is therefore conditional approval in April and a full charter in November.

What the charter allows, and what it excludes

The authorization covers custody and payment activities regulated at the federal level. Coinbase has stressed that the entity does not become a commercial bank. It will not take deposits, will not operate as a fractional reserve bank and will not extend loans. The uniform federal status should, however, allow the company to avoid a patchwork of state licenses for certain activities, even though its platform is already available in all 50 states.

Custody and client wallets

The plan is to hold digital assets in segregated wallets dedicated to each client, using a multi-criteria calculation system. A second offering would pool fiduciary funds and digital assets in a common portfolio, enabling transactions while keeping the assets within a qualified custody environment.

“Clear rules and the trust of our regulators and our clients allow Coinbase to innovate with confidence while ensuring appropriate oversight and security.”

Greg Tusar, Vice President of Institutional Products, Coinbase

Integrated services and smart contracts

The entity is expected to integrate custody, financing, trading and staking services provided by other Coinbase companies. It also plans to explore additional payment options and features that let clients interact with certain smart contracts. As part of qualifying as a custodian under SEC rules for investment advisers, custody will be exercised in a fiduciary capacity.

• No insured deposits and no lending
• No fractional reserve banking
• No automatic access to a master account at the Federal Reserve

A New York structure that remains in place

Coinbase Custody Trust Company, a limited-purpose trust company, received its authorization from the New York State Department of Financial Services in 2018. It already allowed securities custody for professionals, including investment advisers. When the federal application was filed, Coinbase said it continued this activity under New York supervision and its BitLicense framework, whose first application dates back to 2015. The filing makes clear, however, that Coinbase National Trust Company must expand custody activity, which is currently mostly housed in the New York entity, without automatically merging the two structures.

Governance, controls and tighter supervision

The planned governance structure includes a board of seven directors, three of whom are independent, and an audit committee subject to OCC requirements. Four senior executives are named: Rick Schonberg (chief executive), Alesia Haas (chief financial officer), Caroline Tarnok (chief risk officer) and Richard Kelly (chief operating and trust officer). Three further functions are planned: compliance, led by Joseph Salama; information security, led by Alan Leung; and anti-money laundering and counter-terrorist financing oversight, led by Cory Howard.

The risk framework rests on three lines of defense: operational responsibility within the businesses, specialized control of compliance and security, and independent internal audit. AML, CFT and sanctions controls must cover the Bank Secrecy Act, the USA PATRIOT Act, Treasury sanctions rules, an risk assessment conducted at least annually, Know-Your-Customer procedures, customer due diligence and enhanced due diligence for high-risk clients, including politically exposed persons.

The charter also strengthens the OCC’s supervisory tools. Regular examinations and tougher compliance requirements could confirm Coinbase’s operational resilience, or expose weaknesses that would need correcting before any expansion of activity.

A large platform with a strong institutional position

Founded in 2012, Coinbase has become the largest crypto exchange in the United States and, according to its filing, the world’s first crypto custodian. It employs more than 4,200 people and serves clients in more than 100 countries. Listed on the Nasdaq under the ticker COIN since April 2021, it joined the S&P 500 in May 2025.

The last two figures do not cover the same perimeter and are therefore not directly comparable. BlockEden also reports that Coinbase custodies the assets of nine of eleven spot Bitcoin ETFs and eight of nine Ethereum ETFs, and that its assets under custody reached $300 billion, without a specified reference date. Total assets in Bitcoin ETFs stood at $87 billion, while the U.S. 401(k) retirement market, subject to new rules on crypto access, was estimated at $14 trillion.

Competition is intense. BitGo emphasizes multisignature security, Fidelity Digital Assets is building its own institutional offering, and Circle, issuer of USDC, and Ripple, with its RLUSD stablecoin, complete the field. Commercially, USDC accounted for about 20% of Coinbase’s revenue in the third quarter of 2025, and the announced acquisition of Deribit for $2.9 billion strengthens its derivatives offering.

A wave of approvals and banking opposition

Coinbase is part of a series of approvals made possible by the GENIUS Act, signed in 2025. The law creates a federal framework for stablecoins, recognizes national trust banks as eligible issuers and places qualified issuers under OCC supervision. The timeline of authorizations is summarized below.

CoinDesk estimates that this acceleration took 83 days from the start of the wave to Coinbase’s conditional approval. Morgan Stanley, Payoneer and Zerohash filed applications between February and March 2026. Based on available information, the other companies cited remain at the conditional or provisional stage.

The oldest precedent is Anchorage Digital, which received its charter in January 2021, a few days after an OCC interpretive letter allowing trust banks to conduct activities beyond their fiduciary obligations. Jonathan Gould, then a senior OCC official and now the Comptroller of the Currency, defended that opening during the approval of Circle.

“New entrants to the federal banking sector are good for consumers, the banking industry and the economy.”

Jonathan Gould, Comptroller of the Currency, OCC

Within the banking sector, the reaction has been hostile. Trade groups asked the OCC in July to delay decisions on charter applications. Mickey Marshall, deputy senior vice president and regulatory counsel at the Independent Community Bankers of America (ICBA), described the applicants as “risky institutions seeking to attract insured deposits into deposit-like accounts that are uninsured and offer few consumer protections”, and called for the 2021 letter to be withdrawn along with a formal rulemaking. The ICBA subsequently filed a lawsuit against the OCC, accusing it of exceeding its authority by granting these charters.

Conclusion: outlook and scenarios

The full charter places Coinbase in an unusual position: a platform born in crypto that now operates under federal banking supervision. In a favorable scenario, this integration eases payments, institutional custody and products for retail clients, while reassuring investors who want a clear regulatory framework. In an intermediate scenario, the charter’s impact remains mostly operational, with OCC examinations confirming existing standards without changing the business model.

The most demanding scenario relates to litigation and upcoming examinations. If the ICBA lawsuit succeeded, or if controls revealed compliance weaknesses, the timetable for expanding activities could slow. Finally, the sources provide no quantified move in the Coinbase share price or in any crypto asset on November 9, 2026, so it would be premature to draw conclusions about the market reaction to the announcement.

Sources

• CoinDesk, Coinbase gets full U.S. trust charter (November 9, 2026)
• Yahoo Finance, Coinbase gets conditional approval
• Bloomberg, Coinbase says it wins conditional US approval (April 2, 2026)
• OCC, Coinbase National Trust Company filing
• Banking Dive, Coinbase pursues OCC trust charter
• BlockEden, Coinbase OCC national trust bank charter (April 3, 2026)

Cet article est publié à titre informatif et éducatif. Il ne constitue en aucun cas un conseil en investissement. Faites vos propres recherches (DYOR) avant toute décision.