Coinbase’s national trust charter takes effect under OCC oversight

Coinbase said the Office of the Comptroller of the Currency (OCC) gave final approval to its national trust charter on Friday, November 6, putting its custody business on a path into a federal regulatory framework. The company announced the approval on November 9 in its Coinbase National Trust Company announcement. The OCC’s public filing record lists the charter as consummated and effective November 6.

What does the national trust charter let Coinbase do?

It lets Coinbase National Trust Company hold and manage customer assets as a fiduciary under OCC oversight. A fiduciary must act in the interests of the clients whose assets it holds. In its April conditional approval, the OCC described a plan focused mainly on digital-asset custody for institutional clients, with related services to accept, hold and transfer cash and crypto within those customers’ custody accounts.

The process works in steps: a client places assets in a custody account; the trust company safeguards them and handles permitted transfers; and the client can access certain related services offered by Coinbase affiliates. The OCC’s approval described the trust company as a “finder” for services such as staking, prime trading and financing. The affiliates, rather than the trust company, would provide those services.

Think of the trust company as a federally supervised vault with a limited set of connected services. The analogy stops there: the OCC’s order subjects custody to fiduciary duties and limits the company to trust operations and related activities.

Does this make Coinbase a conventional bank?

No. The OCC’s April order described the proposed entity as a non-insured national trust bank. It does not authorize the company to operate as a full-service deposit bank. Cash held for custody customers would sit in “for benefit of” accounts at third-party banks, according to the order; the trust company itself would not hold that cash as ordinary insured deposits.

The distinction matters because a trust charter changes the federal oversight of custody without turning the exchange into a retail bank. Customers would use the entity to safeguard and move assets in custody, not to open ordinary checking accounts or obtain loans from it.

What changes now for Coinbase’s custody business?

The charter gives Coinbase a federal framework for the trust company’s activities. Coinbase said it expects the approval to let it expand its custody business under that framework. The OCC’s earlier order said Coinbase planned to move its existing custody business from Coinbase Custody Trust Company, a New York state-chartered limited-purpose trust company, to the national trust bank over a three-year period.

The final approval completes a regulatory step; it does not by itself establish when customer accounts will move. Coinbase’s announcement did not give a migration date. For institutional clients, the practical change is the federal charter and oversight structure around the planned custody service.

Sources and documents

• Coinbase National Trust Company announcement — coinbase.com
• filing record — apps.occ.gov