U.S. National Trust Bank Charter Applications — State of Play

The "five" (OCC News Release 2025-125, Dec 12, 2025). Conditionally approved in one batch: Circle, Ripple (de novo) and BitGo, Fidelity, Paxos (conversions). A structural contrast: Circle and Ripple do not issue a stablecoin at the bank — the bank only manages the reserve "on a directed basis" and acts as collateral trustee, while the affiliated NY trust company issues USDC/RLUSD. BitGo, Fidelity, and Paxos each propose to issue a stablecoin at the bank. Circle has reached final approval (July 10, 2026); the other four remain conditional/pre-opening. Note the capital conditions scale with the business: from ~$6M (Circle, Laser Digital) up to $60M (Coinbase).

Cross-cutting roadblocks worth watching. Three structural headwinds cut across the pipeline: (1) the Federal Reserve's "payment account" (skinny master account) proposal, formally out since May 20, 2026, has effectively paused ordinary master-account approvals for uninsured national trust banks — cited by Wise as making its original model non-viable; the comment period closed July 27, 2026. The Fed has separately directed Reserve Banks to freeze all Tier 3 master-account applications through December 31, 2026 — nationally-chartered trust banks without a Fed-regulated holding company sit in Tier 3, so the freeze effectively covers this whole cohort. Proposed accounts would bar interest, discount-window access, and daylight overdrafts, with an overnight-balance cap (proposed: lesser of $500M or 10% of the holder's total assets); Fed Gov. Waller has targeted a final rule by end of 2026. (2) an organized opposition campaign by ICBA (urging the OCC to pause all NTB approvals), the Bank Policy Institute, and NCRC, all challenging the OCC's statutory authority to charter uninsured, non-fiduciary crypto trust banks outside the Bank Holding Company Act framework; and (3) the GENIUS Act's statutory July 18, 2026 deadline for final implementing rules was missed — Comptroller Gould committed on August 19, 2026 to publishing the OCC's final stablecoin rules by November 2026, and reaffirmed that target at the Wyoming Blockchain Symposium this week: "We are very intent on moving quickly and getting a final rule out by November so that we will be able to start processing applications within the new year." The OCC's BSA/AML/sanctions NPRM and the related five-agency Customer Identification Program proposal closed for comment August 21, 2026; Treasury separately opened comment on August 17, 2026 on AML and sanctions duties for stablecoin issuers, running to October 19, 2026. On current timing the Act takes effect around January 2027 (the earlier of 18 months after enactment or 120 days after final rules).

New this pass — a filing can now vanish without a decision. Under OCC Bulletin 2026-27 ("Filing Decision Process," June 17, 2026; NR-OCC-2026-47), the OCC may return a materially deficient filing before any meaningful processing — no decision, no press release, no Corporate Decision number. Zerohash is the first NTB applicant this has happened to (returned July 17, 2026; surfaced publicly ~August 12), and it refiled on August 19 under a new control number with a deliberately narrowed scope. Because returns are not announced, removal from the OCC's Digital Assets Licensing Applications index is the only public signal — which is how it was caught. But the refiling exposes the opposite failure: six days later that index still did not list it, though the OCC had recorded the application and opened a comment period. The index catches removals and lags additions, so it cannot be the only check. Every pending applicant carries this procedural risk alongside conditional approval and denial.

New this pass — the NTB charter now has a cheaper competitor, and it is the operating subsidiary. In Corporate Decision #1388 (letter dated July 23, 2026, published September 2026) the OCC approved SoFi Bank, N.A. to establish an operating subsidiary under 12 CFR 5.34(e) that will "engage in the issuance and redemption of payment stablecoins, including payment stablecoins that are branded by Bank and payment stablecoins issued on behalf of third-party clients" — white-label issuance included. The regulatory load is a fraction of what this cohort carries: one condition (GENIUS Act conform / cease / divest, enforceable under 12 USC 1818) and a 12-month deadline to establish the subsidiary. No capital minimum. No eligible-liquid-asset floor. No 180-day operating-expense reserve. No senior-officer vetting condition. No three-year condition period. Set that against an NTB stablecoin issuer — $15M to $60M in Tier 1, at least half of it in eligible liquid assets, 180 days of wind-down operating expenses on top, officer no-objections, and a 12-/18-month expiry clock. Two consequences worth tracking: an entity that already holds a full-service national charter reaches stablecoin issuance far more cheaply than an NTB applicant can; and it lands directly on the white-label NTB models — Bastion and Agora — whose pitch is issuing on behalf of third parties. OpenReserve intends exactly this structure, and CD #1389 confirms its subsidiary application has not yet been filed. SoFi's 2022 charter originally carried a condition barring crypto-asset activities; SoFiUSD launched in December 2025 and reached retail members in May 2026, so CD #1388 formalises and extends a live business rather than starting one.