Key takeaways
- A national trust charter lets a firm hold assets for others under OCC supervision but, in the OCC's design, not take deposits or make loans. A full national bank charter allows deposits, lending and payments, with FDIC insurance and heavier oversight.
- State money transmitter licenses are issued state by state, with one license required in each state where a firm operates.
- Fed master accounts, which give direct access to the central bank's payment system, are limited to depository institutions, so an uninsured trust bank is not eligible.
- The trust-charter route is being challenged in court: the ICBA sued the OCC on October 2, 2026 arguing the agency exceeded its authority.
| Aspect | OCC national trust charter | Full national bank charter | State money transmitter license |
|---|---|---|---|
| Who grants it | Office of the Comptroller of the Currency (federal). | Office of the Comptroller of the Currency (federal). | Each state's regulator, through the NMLS system, in 49 states, D.C. and territories. |
| What it allows | Custody, fiduciary work, settlement, staking, escrow and stablecoin issuance. No deposits or lending. | Deposits, lending, payments and, as a depository institution, Fed master account eligibility. | Money transmission, stored value and, in many states, crypto activity. No deposit-taking is listed. |
| Deposit insurance | Not applicable: no deposits are taken. | Yes, through the FDIC. | Not addressed in our sources. |
| Supervision | OCC. | OCC and FDIC, with Federal Reserve oversight of a holding company. | State regulators, each under its own rules. |
| Scope | One federal framework instead of separate state filings. | One federal framework. | Separate license and filing in each state; New York adds its own BitLicense. |
| Typical timeline (reported estimates) | Roughly 4 to 8 months. | A decision often within 120 days, then up to about 18 months to organize. | From 3 to 24 months per state. |
| Examples in the news | Circle National Trust (final approval July 10, 2026); conditional approvals in December 2025 for Ripple, Paxos, BitGo and Fidelity Digital Assets, and in February 2026 for Crypto.com and Bridge. | Erebor Bank; OpenReserve Bank, which received a full national bank charter in September 2026, per CoinDesk. | Held by many payments and crypto companies; varies by company and state. |
Sources: ChainBrief's OCC charter reporting; CoinDesk and American Banker on the ICBA lawsuit; a secondary legal wiki (wiki.private.law) for activities, supervision and timeline estimates, which are estimates and vary by applicant. Check the OCC and state regulators for current rules.
The simplest way to tell them apart
Think of the three licenses by what they let a company do with your money. A trust charter lets a firm hold assets on someone's behalf and act as a fiduciary, but not take deposits or lend them out. A full bank charter does all of that and more, which is why it carries deposit insurance and heavier requirements. A state money transmitter license lets a company move or store value for customers, but it is granted state by state and does not make the company a bank.
Why crypto firms keep choosing the trust charter
As we reported in our look at the federal charter race, the national trust charter became the clearest signal that a crypto firm is a legitimate, federally supervised custodian. It replaces a patchwork of state filings with a single federal perimeter, and it fits businesses whose core activity is custody and settlement. It also has limits. An uninsured trust bank does not qualify for a Federal Reserve master account, which is reserved for depository institutions, and the OCC's description of the charter excludes deposits and lending.
Why not just get a bank charter?
A full national bank charter is harder to obtain and brings deposit insurance, lending rules, and a larger set of regulators. In exchange, the firm can offer deposit accounts and has a route to central-bank payment access. Reported estimates suggest the process can take longer once organization time is counted. Erebor Bank and OpenReserve Bank are examples of crypto-linked firms that pursued or received full charters.
The state route
State money transmitter licenses remain the foundation for many payments and crypto companies. The cost is repetition: each state has its own application, standards and timeline. New York has its own BitLicense, and its limited-purpose trust company route is separate again. The CFTC's recent notice on crypto exchanges contrasts a federal framework with state money-transmission licensing, which is one reason federal charters have drawn so much interest.
The legal challenge
On October 2, 2026, the Independent Community Bankers of America sued the OCC in federal court in Washington, arguing that the agency exceeded its authority under the National Bank Act by chartering trust banks for firms whose business is not traditionally fiduciary. No court has ruled, and the OCC does not comment on litigation. We cover the case in our report on the lawsuit. A court outcome could change which of these routes are realistic for a crypto firm, so this page will be updated as the case develops. For background on the agency, see our OCC profile and the glossary entry on national trust bank charters.
What this means for customers
Which license a company holds changes what protections apply to you. Deposit insurance applies to deposits at insured banks. The SEC's investor bulletin on crypto custody does not describe crypto held in custody as insured and tells investors to ask any custodian about insurance for loss or theft and what its terms are. This is general information, not legal or financial advice.
Frequently asked
Can a company with a national trust charter hold my deposits?
Not in the OCC's design: a national trust charter allows custody and fiduciary-type services but not deposit-taking or lending. A company that wants to offer deposit accounts would need a full bank charter or a partnership with an insured bank.
Is crypto held at a trust bank FDIC-insured?
FDIC insurance applies to deposits at insured banks, and a trust bank without deposits does not carry it. The SEC's custody bulletin tells investors to ask custodians about any insurance for loss or theft and to read its terms.
Does a federal charter replace state licenses?
A federal charter provides a single federal framework in place of separate state money-transmission filings for covered activities, but the exact reach depends on the activities involved and on rules that are still being litigated and written. Check with the regulators and the company.
Further reading
- American Banker: ICBA sues OCC over trust charters
- private.law wiki: US financial and crypto licenses, three axes of choice (secondary source)
- SEC Investor.gov: Crypto asset custody basics for retail investors
- ChainBrief: The race for a federal crypto bank charter
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