Coinbase National Trust Opens Under Final OCC Approval

Coinbase National Trust Company is open as a federally chartered fiduciary crypto custodian. In a letter dated 6 November 2026, the Office of the Comptroller of the Currency granted “final conditional approval of the application to charter Coinbase National Trust Company” and said the organisers “are authorized to open the Bank on November 9, 2026.” Coinbase said the same day that it had “received final approval” and had launched the company.

That is a tighter status than a new all-purpose bank. The OCC’s conditions require the institution to “limit its operations to those of a trust company and activities related thereto,” and not to meet the Bank Holding Company Act definition of “bank.” It will “provide cryptocurrency custody in a fiduciary capacity.” The April preliminary decision already sat on TSN as Coinbase’s conditional trust-charter approval. This is the final step that authorised the doors to open, not a conversion into a full-service bank.

The OCC authorised a 9 November opening, with capital and liquidity conditions attached

The final letter, addressed to Coinbase National Trust president and chief executive Rick Schonberg, says the organisers had met the pre-opening requirements tied to the 2 April 2026 preliminary conditional approval. The OCC’s Corporate Applications Search record for control number 2025-Charter-343449 lists the filing as received on 3 October 2025, approved on 2 April 2026, and “Consummated/Effective” on 6 November 2026. The proposed charter number is 25390, with its main office at One Madison Avenue in New York, and trust powers requested.

The conditions that now supersede the April set are specific. The bank must maintain a minimum of $60 million in tier 1 capital, of which the greater of 50 percent of that capital or $30 million must be held in Eligible Liquid Assets, and it must hold 180 days of operating expenses in Eligible Liquid Assets that are not double-counted against that capital buffer. Both conditions last through the first three years of operation. “If and to the extent necessary,” it must also conform, cease or divest activities to comply with the GENIUS Act and the OCC’s implementing rules, “such compliance to be determined in the sole discretion of the OCC.”

Coinbase’s blog, signed by Schonberg, frames the charter as bringing “clear and consistent federal uniformity” to custody work that has been done under New York’s limited-purpose trust regime since 2018. That is the company’s case for the move. The OCC letter is the document that actually limits what the new entity may be.

Custody accounts are to migrate from the New York trust company over time, not in a disclosed completed transfer

The November letter records a Master Assignment and Assumption Agreement dated 1 September 2026 between Coinbase Custody Trust Company, LLC — the New York State Department of Financial Services-chartered vehicle that today serves Coinbase Prime clients — and the new national trust company. It “provides for the transition, over time, of the rights and responsibilities associated with these services.” The bank “intends to commence migration of client custody accounts and client digital assets.” No completed transfer totals, dates or share of the book are disclosed in the letter or in Coinbase’s 9 November post.

That matters because a federal charter can be read, carelessly, as if the clients have already moved. They have not been shown to have done so. The April preliminary letter had described a plan to migrate “the entirety of this custody business” over the three-year de novo period. The final letter is more spare: a contract exists, and migration is intended to start. Until Coinbase or the OCC publishes a completed transfer, the conservative reading is the one on the page.

The same caution applies to the comparison with Ripple’s claim of final OCC approval for its own trust bank. Parallel federal trust charters are a genuine trend. They are still trust companies, not a new class of insured commercial banks, and each firm’s migration timetable is its own.

The next documents to watch are a disclosed client-migration update and any OCC determination under the GENIUS condition. The charter is in force. The book has not been shown to have followed it yet.

Sources

1. Office of the Comptroller of the Currency, Corporate Decision #1370, final conditional approval letter, 6 November 2026. https://www.occ.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1370.pdf
2. Coinbase, “Coinbase launches National Trust Company with federally regulated, institutional-grade custody offering,” Rick Schonberg, 9 November 2026. https://www.coinbase.com/blog/coinbase-launches-national-trust-company-with-federally-regulated-institutional-grade-custody-offering
3. OCC Corporate Applications Search, control no. 2025-Charter-343449. https://apps.occ.gov/CAS/home/details?FilingID=3RAoRRek6o4j&FilingSubtypeID=1093&FilingTypeID=2

Related stories

Coinbase Gets Conditional US Approval for Trust Charter is TSN’s April account of the preliminary approval that this final letter completes.

Also relevant:

• Ripple Says It Has Won Final OCC Approval for Its Trust Bank
• OCC Finalises GENIUS Act Stablecoin Rule, With AML Rules Still to Come