Coinbase’s newly effective US national trust bank charter carries a $60 million minimum Tier 1 capital requirement, a three-year plan to transfer its existing custody business and restrictions that keep the entity separate from ordinary retail banking. Those terms appear in the Office of the Comptroller of the Currency’s published approval decision, providing a more detailed picture of the authority granted to Coinbase National Trust Company.
The OCC’s corporate applications record lists the charter as effective on November 6, 2026, after the application was filed on October 3, 2025, and conditionally approved on April 2, 2026. Coinbase confirmed the final sign-off on November 9. The new regulatory status comes as the Independent Community Bankers of America (ICBA) continues to oppose the OCC’s approach to chartering digital-asset trust banks.
Coinbase Charter Effective Date Confirms Final OCC Approval
The regulator’s application record identifies Coinbase National Trust Company as a national trust bank headquartered in New York, with proposed charter number 25390. Its November 6 effective date is distinct from the preliminary conditional approval granted in April.
In its November 9 announcement, Coinbase described the move as bringing its established digital-asset custody activities under a consistent federal framework. Rick Schonberg, who authored the announcement, said federal supervision would bring custody closer to the financial infrastructure institutional clients use. For the initial confirmation of the decision, see BlockBriefing’s earlier report on the final charter approval.
Capital And Liquidity Conditions Define The New Bank
The OCC’s April 2 decision, Corporate Decision No. 1370, specifies that the trust bank must maintain at least $60 million in Tier 1 capital. The greater of $30 million or 50% of Tier 1 capital must be held in eligible liquid assets. Those requirements apply during its first three years of operation.
The bank must also hold eligible liquid assets covering 180 days of operating expenses, separately from the liquidity already required against its capital buffer. The OCC defines eligible holdings narrowly, including unencumbered cash, certain short-dated deposits at insured institutions and US government obligations maturing within 90 days. The supervisory decision also calls for quarterly assessments of whether additional capital and liquidity are needed as the risk profile changes.
These are conditions in the published preliminary approval decision; the final effective-date entry does not itself publish a revised set of capital terms. The figures should not be described as the value of assets Coinbase customers have deposited or as a federal guarantee against cryptocurrency losses.
Custody Migration Will Take Up To Three Years
Coinbase’s existing institutional custody business operates through Coinbase Custody Trust Company, LLC, a New York limited-purpose trust company. Under the approved plan, the company intends to transfer the entire custody business to the newly chartered federal trust bank over the three-year de novo period.
The OCC decision says the trust bank will hold digital assets in a fiduciary capacity, primarily for institutions. Custody-account customers may also accept, hold and transfer fiat currency and digital assets associated with those accounts. The regulator’s document does not specify when the first customers will move, and Coinbase’s public announcement does not provide a customer-by-customer transfer schedule.
The federal entity may refer its custody customers to staking, Coinbase Prime trading and financing services supplied by affiliates. The OCC explicitly states that the trust bank will not itself provide those underlying affiliate services. That separation matters when identifying which legal entity is responsible for a particular service.
Federal Trust Charter Does Not Permit Retail Deposits
Despite the word “bank” in its charter, Coinbase National Trust Company is not being authorized to operate as a conventional deposit-taking commercial bank. Coinbase said at the conditional-approval stage that it would not accept retail deposits or engage in fractional-reserve banking. The OCC’s decision limits the entity to trust-company activities and related services described in its plan.
When fiat currency is held in custody, the decision says those balances will sit in “for benefit of” accounts at third-party banks. It also describes the national trust company as an uninsured institution. The charter itself therefore does not give cryptocurrency custody holdings FDIC deposit protection. Customers need to assess the specific account agreement, custody arrangement and protections associated with their assets.
Federal chartering also is not interchangeable with proof of asset backing. BlockBriefing previously examined what proof-of-reserves disclosures can and cannot establish about a crypto firm’s financial position.
Stablecoin Plans Require Regulatory Review Beyond Current Approval
The OCC’s decision contains an important limitation on stablecoins: the bank’s submitted business plan did not propose issuing stablecoins. Any significant deviation from that business plan requires at least 60 days’ prior written notice and the regulator’s written determination of no objection, subject to the terms described in the letter.
That means the trust charter should not be read as an automatic authorization for Coinbase National Trust Company to launch its own stablecoin. Any future changes involving issuance or other materially different operations would have to be evaluated under applicable law, including the GENIUS Act and OCC requirements.
Coinbase’s wider business already has substantial USDC market price and chart activity, which is distinct from any new authority granted to this trust entity. The company reported an average of $22 billion in USDC held in Coinbase products during the third quarter of 2026, up 49% year over year.
Banking Group Questions Expanded Trust Charter Regulatory Powers
The ICBA issued a statement on November 9 opposing the reported final approval. Its president and chief executive, Rebeca Romero Rainey, argued that the OCC’s trust charter interpretation allows nontraditional institutions to provide deposit-like services without the same rules that apply to community banks.
The association also referred to a separate legal case involving allegations about prediction-market operations at a Coinbase affiliate. Those allegations concern a different legal entity and are not findings that Coinbase National Trust Company breached the conditions of its charter.
The OCC reached a different conclusion in its published decision. It said national trust banks can conduct fiduciary custody under existing law and that the regulator had assessed the proposed management, compliance arrangements and operational risks. Its document records five public comments and explains why they did not warrant rejection of the application. The disagreement is therefore over how federal trust-bank powers should be interpreted and supervised, rather than whether the November 6 effective date appears in the regulator’s records.
Company Financial Data Shows Broader Institutional Exposure Today
The regulatory approval arrives at a point when Coinbase’s institutional footprint is substantial. The company’s third-quarter results released on October 29 show that Coinbase’s crypto trading volume market share reached 10.7%, while assets on platform represented 12.5% of total cryptocurrency market capitalization.
Its investor-relations dashboard lists $377 billion in assets on platform as of September 30, 2026. This measure encompasses the broader platform and must not be confused with assets already held by the new national trust company. Separately, the company reported third-quarter net income of $719 million and subscription-and-services revenue equal to 49% of net revenue. BlockBriefing also covered Coinbase’s third-quarter profitability and product diversification.
The numbers help explain why the transition of custody operations matters to asset managers, trading counterparties and other institutions. They do not indicate that all Coinbase products will now be supervised as part of the trust bank.
What Institutional Clients Should Watch After Charter Approval
The next evidence to watch is operational: disclosures identifying when existing custody customers move to Coinbase National Trust Company, updated custody agreements, regulatory reporting and any OCC-reviewed changes in the approved business plan.
For institutions, the central difference is a federally chartered fiduciary custodian subject to specific capital, liquidity and supervisory requirements. For retail customers, the approval does not by itself create a new insured bank account or expand deposit protections. The OCC’s public records establish the charter milestone; the practical effect on individual customer arrangements will depend on subsequent implementation and contractual documents.
Primary documents: OCC Corporate Applications Search, OCC Corporate Decision No. 1370, Coinbase’s November 9 statement, ICBA’s November 9 response and Coinbase’s Q3 2026 financial disclosure. Information current as of November 11, 2026.
