Key Takeaways
- Crypto firms can apply for federal bank charters.
- Applications still face full regulatory review.
- Trust banks and insured deposit-taking banks follow different paths.
- Digital-asset companies are already in the OCC pipeline.
Crypto Firms Are Already in the Charter Pipeline
Gould’s comments arrive with a growing digital-asset licensing queue already visible at the OCC.
OCC Crypto Trust Bank Pipeline
A National Trust Bank Is Not a Full-Service Bank
Many crypto firms seeking federal banking status are not trying to become conventional banks that take retail deposits and make ordinary loans.
Where the FDIC Fits In
The regulatory path changes when insured deposits enter the picture.
The new OCC announcement specifically praises the FDIC’s effort to make that process clearer for new banks. Chairman Travis Hill has also said the agency wants to encourage de novo formation and approach innovative business models with an open mind while keeping the statutory standards for insured institutions intact.
- A national trust charter can support permitted custody and trust activities without necessarily involving insured deposits.
- An insured deposit-taking national bank must obtain its OCC charter and separately satisfy the FDIC’s deposit-insurance process.
The FDIC changes are therefore most directly relevant to digital-asset applicants that plan to take federally insured deposits.
Crypto Is No Longer Supposed to Fail the Test Before It Starts
Federal supervisors are also moving away from using reputation risk to restrict relationships with lawful businesses.
The OCC and FDIC have removed reputation risk as a basis for adverse supervisory action, shifting the focus toward identifiable financial, operational and compliance risks instead of whether a business is politically controversial.
Digital-asset applicants still have to demonstrate competent management, adequate financial resources and controls capable of handling sanctions, money laundering, cybersecurity and operational risks.
For crypto, the practical change is straightforward: exposure to digital assets should trigger a risk assessment, not an automatic stop sign.
Federal Banking Is Becoming a Real Option for Crypto
Many U.S. crypto businesses have historically operated through combinations of state money-transmission licences, state trust charters and specialist regulatory regimes.
A national charter offers a different route: an OCC federal charter and a framework for bringing permitted activities such as custody, settlement and related financial services into the national banking system.
The trade-off is heavier supervision. Firms choosing that path accept bank-level regulatory scrutiny in exchange for operating within an established federal structure.
The growing application queue shows that some of the industry’s largest infrastructure providers consider that worthwhile. Gould’s “open for business” message now has a measurable test: which of those applicants can satisfy the OCC’s standards and make it through the charter process.
