Coinbase’s national trust charter takes effect under OCC oversight

Coinbase said on Nov. 9 that the Office of the Comptroller of the Currency (OCC) had finalized a national trust charter for Coinbase National Trust Company, effective Nov. 6, according to the OCC’s application record. The approval places Coinbase’s planned trust activities under a federal banking regulator, but it does not turn the exchange into a deposit-taking commercial bank.

The OCC record identifies this as a new national bank charter under a holding company, in the trust-bank category. It lists Coinbase National Trust Company as the proposed bank, with charter number 25390, and records its status as “Consummated/Effective” on Nov. 6. Coinbase announced the final approval three days later.

What business does the charter cover?

The charter covers fiduciary cryptocurrency custody and related services, based on the business plan the OCC reviewed. In its April conditional approval, the regulator described custody customers as being able to accept, hold and transfer fiat currency and digital assets held in their accounts. The services are limited to custody customers and the assets in those accounts, the OCC said.

That design connects the trust company to Coinbase’s existing institutional custody operation without making the trust company a general-purpose bank. The OCC’s April decision said fiat held in custody would sit in “for benefit of” accounts at third-party banks. It also said the trust company could facilitate custody clients’ access to affiliate services, including staking, prime trading and prime financing, where those services relate to assets held in custody.

Coinbase described the federal charter as a way to bring its custody business under a consistent national framework, building on its prior oversight in New York. In its Nov. 9 announcement, the company said the OCC approved its application the previous Friday. That statement and the OCC’s effective date establish both the announcement date and when the charter took effect.

Does the charter let Coinbase take deposits or issue stablecoins?

No: the OCC’s April decision describes a trust company limited to trust operations and related activities, rather than a full-service bank that takes deposits and makes commercial loans. The decision also states that Coinbase National Trust Company did not propose to issue stablecoins. Those limits matter because the charter’s scope is defined by custody and closely related services, not by every product Coinbase offers through other entities.

The trust company’s fiduciary custody is subject to fiduciary duties and standards of conduct, according to the OCC. The regulator also said it would supervise compliance with applicable laws and examine the institution. The federal charter therefore sets a regulatory framework for this entity’s custody activity; it does not, by itself, establish that every Coinbase product or affiliate operates under the same charter.

What changes for Coinbase’s custody customers?

The immediate change is the regulatory home for the trust company: its charter is now effective under the OCC, rather than remaining at the conditional-approval stage Coinbase entered in April. The OCC’s application record confirms the transition, while Coinbase says the federal framework will support its custody business.

The records reviewed do not specify when Coinbase will move custody accounts into the new trust company or set a customer migration schedule. They also do not say that customer assets will become bank deposits. For clients, the confirmed development is narrower: Coinbase now has an effective federal trust charter for a company whose stated activities center on fiduciary digital-asset custody and related services.

Sources and documents

• OCC’s application record — apps.occ.gov
• Nov. 9 announcement — coinbase.com