Coinbase has filed for a National Trust Company charter with the Office of the Comptroller of the Currency, a move that would reframe its U.S. regulatory posture by enabling fiduciary custody and trust services without converting the company into a traditional depository bank; the application, submitted on October 3, 2025, is positioned to strengthen institutional custody capabilities, streamline fiat on- and off-ramps previously reliant on partner banks, and underpin new payment and hybrid crypto-traditional products under a clear federal framework. The filing seeks a federal trust charter rather than a full commercial banking license, and Coinbase has publicly reiterated that it does not intend to become a traditional bank, a distinction intended to preserve its operational model as a non-depository institution focused on custody, asset management, and payment integration. Coinbase continues to operate under the New York BitLicense framework while the OCC reviews the petition The National Trust Company charter would authorize fiduciary and trust activities while stopping short of permitting broad deposit-taking and lending operations typical of depository banks, enabling Coinbase to formalize custody arrangements for institutional investors, meet heightened prudential standards, and offer compliant payment rails tied to digital asset flows. By reducing dependence on third-party correspondent banks for fiat on- and off-ramps, the charter could streamline settlement pathways and reduce operational fragmentation, potentially improving liquidity handling and operational resilience across jurisdictions under federal supervision. This approach also helps navigate the global regulatory challenges that crypto firms face due to inconsistent government rules. Coinbase frames the application as part of a broader industry shift, joining other crypto firms and select fintechs pursuing federal charters to clarify regulatory status, foster institutional confidence, and accelerate product innovation. The move reflects convergence between traditional finance and digital asset markets, where regulated trust status can serve as an intermediary regulatory posture for firms seeking to operate within the financial system without adopting full banking functions. Operational implications include expanded capacity to directly manage fiat inflows and outflows, new payment products that bridge fiat and tokenized assets, and enhanced fiduciary responsibilities tied to trust law. Leadership emphasizes regulatory clarity as foundational to responsible innovation, while acknowledging that charter approval timelines and supervisory expectations remain uncertain. If granted, the charter could set a precedent for hybrid business models, but it would also invite rigorous OCC oversight and require sustained compliance investments to meet trust-level prudential standards. The application is also attractive to crypto firms because the National Trust Charter emphasizes fiduciary status and regulatory clarity rather than full commercial banking.
