# Coinbase Regulatory File [[Coinbase]]'s cases, charters and fights with government, newest developments noted in each section. ## The SEC lawsuit (2023–2025) The [[SEC]], then led by Gary Gensler, sued Coinbase in federal court in Manhattan on **June 6, 2023**. It argued that tokens traded on Coinbase were securities and that Coinbase was running an unregistered exchange, broker and clearing agency. In March 2024 a judge let most of the case go forward. After the 2024 election the SEC changed course. On **February 27, 2025** it agreed to dismiss the case, saying the decision was "not on any assessment of the merits" but part of an effort to reform its approach to crypto. Press reports said the dismissal was with prejudice, meaning the case cannot be refiled. The SEC is now led by [[Paul Atkins]]. ## State cases - **Staking orders.** Several states moved against Coinbase's staking program, in which customers lock up tokens to earn rewards, in June 2023. Alabama, Kentucky, Illinois, South Carolina and Vermont withdrew their actions in March and April 2025. On October 29, 2026, New Jersey told Coinbase it intends to rescind its order. California, Maryland, Washington and Wisconsin are still pending. - **Oregon.** Oregon's attorney general sued Coinbase on April 18, 2025 under state securities law. Coinbase moved the case to federal court; a magistrate judge recommended in September 2025 that it go back to state court. Its status in 2026 is not clear. - **Customer class action.** In a long-running customer suit in Manhattan federal court (Underwood), the judge ruled for Coinbase on most of the transactions on July 30, 2026; claims over the rest continue. ## The national trust bank charter Coinbase applied in early October 2025 for a national trust charter for **Coinbase National Trust Company**, a New York bank that would hold digital assets for institutional clients. It would not take insured deposits. The [[OCC]], the federal regulator of national banks, gave **conditional approval on April 2, 2026** (decision no. 1370). | Condition | Requirement | |---|---| | Capital | At least $60 million of core (Tier 1) capital | | Liquidity | Liquid assets of at least half its core capital or $30 million, whichever is greater, plus 180 days of operating expenses, for three years | | Law | Its activities must comply with the [[GENIUS Act]] | | Oversight | 60 days' notice of major business changes; OCC sign-off before naming senior officers or directors | | Deadlines | Raise capital within 12 months and open within 18 months (by about October 2027), or the approval expires | Coinbase does not plan to issue stablecoins through the bank; the OCC set aside public comments about stablecoins for that reason. **Opposition.** The Independent Community Bankers of America, the Bank Policy Institute (both bank lobbies) and the National Community Reinvestment Coalition filed objections in early November 2025. The coalition condemned the approval on April 3, 2026, and the community bankers asked the OCC to rescind it in late May 2026. No final approval had been reported as of October 31, 2026. For the other 24 charters approved in the same period, see [[OCC Charter Wave]]. ## The 2025 data breach On May 11, 2025, Coinbase received a $20 million extortion demand from criminals who had bribed overseas customer-support contractors and employees to steal customer data. Coinbase disclosed the breach to investors on May 14, refused to pay, and offered a $20 million reward for information leading to arrests instead. - It first estimated the cost at $180–400 million. The actual 2025 loss was **$345.2 million**, which included reimbursing customers who were tricked into sending funds to scammers. - It recovered a net $43.7 million in the first nine months of 2026. - The first arrest, in India, was announced in December 2025. Customer-support contractor TaskUs has been sued over the breach. ## The CLARITY Act fight The [[CLARITY Act]] would set the rules for crypto trading markets and split oversight between the SEC and the Commodity Futures Trading Commission. Coinbase spent years lobbying for such a law, but turned against the Senate version over **stablecoin rewards**. Coinbase pays customers rewards on USDC; banks want that banned because it competes with interest-bearing deposits. - The House passed its bill 294–134 on July 17, 2025. - On **January 14, 2026**, hours before a scheduled Senate Banking Committee vote, Armstrong pulled Coinbase's support, saying the company would "rather have no bill than a bad bill." The vote was postponed. [[David Sacks]], the White House crypto adviser, publicly urged the industry to settle its differences. - The committee advanced the bill 15–9 on **May 14, 2026**, after a compromise between [[Thom Tillis]] and Angela Alsobrooks that bars rewards for simply holding a stablecoin but allows rewards tied to activity. - A motion to bring the bill to the Senate floor failed 49–50 on **September 15, 2026**, with no Democratic votes in favor. ## Other - **CFTC:** Coinbase paid a $6.5 million penalty to the Commodity Futures Trading Commission in 2021 over false reporting and wash trading by a former employee; no CFTC case was found in 2026. See [[Wash Trading]]. ## Sources - [SEC press release 2025-47](https://sec.gov/newsroom/press-releases/2025-47) · [Q3 2026 quarterly report (10-Q)](https://www.sec.gov/Archives/edgar/data/0001679788/000167978826000122/coin-20260930.htm) - [OCC conditional approval, decision no. 1370](https://comptrollerofthecurrency.gov/topics/charters-and-licensing/interpretations-and-decisions/2026/cd1370.pdf) · [American Banker on bank opposition](https://www.americanbanker.com/news/bank-trade-group-opposes-coinbase-charter-application) · [NCRC, Apr 3, 2026](https://ncrc.org/ncrc-decries-the-occs-granting-of-national-trust-bank-charter-for-crypto-company-coinbase/) · [NCRC on the rescission request](https://ncrc.org/icba-asks-occ-to-rescind-coinbases-conditional-charter-approval/) - [Data breach 8-K, May 14, 2025](https://www.sec.gov/Archives/edgar/data/1679788/000167978825000094/coin-20250514.htm) · [The Block on the first arrest](https://www.theblock.co/post/383790/coinbase-ceo-announces-first-arrest-in-india-over-insider-data-breach-more-still-to-come) - [The Block on the Oregon suit](https://www.theblock.co/post/351262/oregon-attorney-general-to-sue-coinbase-months-after-sec-drops-case-exchange-says) - [The Block, Jan 17, 2026](https://www.theblock.co/post/386061/stablecoin-yield-fight-threatens-to-sink-clarity-act-as-coinbase-and-white-house-clash) · [The Defiant on the Sep 15 vote](https://thedefiant.io/news/regulation/senate-blocks-clarity-act-49-50-with-no-democratic-votes-to-proceed) ## See also - [[Coinbase Dossier]] — the full dossier - [[Cryptocurrency Regulation Timeline]] · [[OCC Charter Wave]] · [[World Liberty Financial Regulatory File]]