According to a May 21 report by Bitcoin.com News, the U.S. Office of the Comptroller of the Currency (OCC) has, beginning in December 2025, approved at least nine crypto companies to obtain national trust bank charters, including BitGo, Ripple, and Coinbase. In May, Senator Elizabeth Warren sent a letter to OCC Director Jonathan Gould, saying the approval actions were “improper.”
OCC confirms approved trust charters: approval conditions and timelines for three companies
Between December 2025 and April 2026, the OCC approved trust charter applications for the following three major institutions, with specific conditions differing for each:
· BitGo received a full, unconditional approval in December 2025, converting the South Dakota trust company into the federally chartered “BitGo Bank & Trust, N.A.,” which can provide digital asset custody services nationwide under a single federal regulatory framework.
· Ripple received a conditional approval in December 2025. “Ripple National Trust Bank (RNTB)” will be based in New York as a wholly owned subsidiary of Ripple Labs. Its business scope includes stablecoin reserve management and trust services, complementing Ripple’s stablecoin RLUSD business.
· Coinbase received a conditional approval in April 2026. “Coinbase National Trust Company (CNTC)” confirmed its positioning as a federally regulated crypto custody institution. It will not become a commercial bank, will not accept retail deposits, and will not perform partial-reserve operations; at this stage, it continues operating under the New York State Department of Financial Services (NYDFS) and the BitLicense regulatory framework.
Warren’s allegations: nine institutions, “regulatory circumvention,” and document disclosure demands
In her letter, Warren characterizes the above companies as “de facto crypto banks, intending to evade the basic protections and obligations that come with bank supervision,” and argues that their business plans go beyond the narrow range of trust activities that national trust banks are legally allowed to conduct. She要求ed the OCC to provide complete documents regarding the approvals for the nine institutions, and to disclose relevant communications between OCC officials and the White House or members of the Trump family. Warren’s review scope includes: Ripple National Trust Bank, Paxos Trust Company LLC, First National Digital Currency Bank, Fidelity Digital Asset Services, BitGo Trust Company, Foris DAX National Trust Bank, National Digital Trust Company, Bridge National Trust Bank, and Coinbase National Trust Company.
Core points of Belshe’s open letter: three legal distinctions for trust custody
In the open letter, Belshe establishes BitGo’s legal position through three clear statements:
“We don’t accept deposits”: BitGo is not a deposit-taking institution. Existing deposit insurance, capital rules, and regulatory obligations under the Community Reinvestment Act are aimed at institutions that borrow from depositors and take on lending risk, not trust custody providers.
“We don’t lend customers’ assets”: Customers’ assets are held in separate accounts not subject to bankruptcy law; BitGo assumes the corresponding trust responsibilities, and does not do maturity transformation or re-collateralization.
“We don’t commingle assets”: Customers’ assets and BitGo’s corporate funds are completely segregated. This forms a fundamental distinction from models that commingle customers’ funds with collapsed crypto companies like FTX.
Belshe also raises doubts about the term “crypto bank,” noting that it is not clearly defined in current law. He argues that the term blurs two fundamentally different risk structures: trust institutions versus partial-reserve banks. He points out that national trust banks have long held assets such as artworks, gold and silver bars, jewelry, farmland, and commercial interests, and that digital assets fit within similarly structured trust frameworks. BitGo obtained a South Dakota trust charter in 2018 and holds regulated entities or licenses in New York, Switzerland, Germany, Dubai, and Singapore.
Regarding stablecoin reserves, Belshe confirms that BitGo fully holds reserves at a 1:1 ratio and does not conduct any lending or maturity transformation, and performs auditor-supported reserve attestations twice per month. There are also quarterly and annual audits, with frequencies higher than those of typical periodic bank audit reports. Belshe concludes: “Asset categories won’t change the structure.” At the end of the letter, he invites Warren to communicate directly with BitGo and its employees, and says the company has spent the past ten years seeking stricter regulation, believing that OCC charters are an extension of the federal layer rather than a route to evade regulation.
Frequently asked questions
What is the fundamental difference between an OCC national trust bank charter and a commercial bank license?
A national trust bank charter authorizes the institution to provide asset custody and trust services, but does not include accepting retail deposits or making loans. A commercial bank license allows an institution to accept deposits and make loans and requires compliance with a comprehensive regulatory framework including deposit insurance, capital requirements, the Community Reinvestment Act, and the Bank Holding Company Act. Belshe’s open letter is precisely framed around defending this legal distinction, arguing that a trust institution’s risk structure is fundamentally different from that of a deposit bank.
How does the GENIUS Act affect OCC’s approval policy for crypto trust charters?
The GENIUS Act was passed in July 2025 and established a federal regulatory framework for stablecoins, clarifying issuers’ reserve requirements and audit standards. After the bill passed, the OCC accelerated its handling speed for crypto trust charter applications. The conditional approval of Ripple National Trust Bank clearly positioned it to complement its RLUSD stablecoin business, directly tying it to the GENIUS Act regulatory framework.
On what basis does Warren request OCC disclosure and communications records with the White House?
In her letter, Warren requested communications records between OCC officials and the White House or members of the Trump family, intending to investigate whether political factors influenced the regulatory approval decision. As of now, the OCC has not publicly responded to this specific request. Warren’s investigation scope currently limits to requesting document disclosures and has not yet proposed any legislative or judicial action.
