# OCC Charter Wave The **OCC Charter Wave** is the run of federal bank and trust-bank charters the [[OCC]] has granted to crypto, stablecoin and fintech companies since [[Jonathan Gould]] was sworn in as Comptroller on **July 15, 2025**. By its own count the OCC received about **40 de novo applications in 18 months**. As of October 8, 2026, this page's ledger counts **25 conditional approvals, 2 denials and 1 returned application**, with more than ten applications pending. The wave matters to this vault because it is where the second Trump administration's crypto politics turns into **institutions**. A token can crash and a PAC can disband, but a national charter carries federal preemption, a path to Federal Reserve payment rails, and the legitimacy that lets institutional money transact with the holder. Two charters in the wave sit directly on networks this vault tracks: - [[Erebor]] — the bank co-founded by [[Palmer Luckey]] and [[Joe Lonsdale]], the first de novo charter of Gould's tenure, approved in four months. Its fundraising memo said "Palmer's political network will get this done." - [[World Liberty Financial]] — the president's family's crypto venture, whose **World Liberty Trust Company** won conditional approval on August 14, 2026 (see [[World Liberty Trust OCC Bank Charter Approval]]). Most of the rest of the wave is ordinary industry: Circle, Ripple, Paxos, Fidelity, Morgan Stanley, Sony. That is the point of tracking all of it. It lets you test the politically connected charters **against the baseline** instead of in isolation. ## How the charter works (stages) 1. **Application.** Filed with the OCC; a public-comment period follows. Bank trade groups file opposition letters on most crypto applications. 2. **Conditional (preliminary) approval.** The OCC agrees to charter the institution *if* it meets conditions, usually a minimum of Tier 1 capital, a liquid-asset floor, an operating-expense reserve, and a deadline to open (typically 18 months). Most of the wave is at this stage. 3. **Final approval and opening.** Capital raised, conditions met, examination passed. Only a handful have reached this stage: [[Circle]] (final July 10, 2026; opened July 24), BitGo (operating as a national trust bank from December 2025), and Erebor (opened February 8, 2026). 4. **Supervision.** Ongoing, confidential examination by the same agency. This is the stage critics of the WLF charter say matters most, because it is invisible. A **national trust bank** (most of the crypto charters) can custody assets and, under the GENIUS Act, issue payment stablecoins, but takes no insured deposits. A **full-service national bank** (Erebor, Mercury, Revolut, OpenReserve) takes FDIC-insured deposits and lends. Erebor is the only crypto-native company in the wave with a full-service charter that is already open. ## The ledger Dates are the OCC decision date where known. "CD" is the OCC corporate-decision number. ⚠️ marks a single-sourced fact. ### Digital-asset and stablecoin trust charters | Company | Entity | Type | Conditional approval | Status | Notable | |---|---|---|---|---|---| | [[Circle]] | First National Digital Currency Bank, N.A. | De novo trust | Dec 12, 2025 | **Final Jul 10, 2026; open Jul 24** | USDC issuer; first of the wave to open as a trust bank | | [[Ripple]] | Ripple National Trust Bank | De novo trust | Dec 12, 2025 | Conditional | RLUSD reserves | | [[BitGo]] | BitGo Bank & Trust, N.A. | Conversion (South Dakota trust) | Dec 12, 2025 | Operating | **Custodian and issuer of USD1**, World Liberty's stablecoin | | Fidelity Digital Assets | Fidelity Digital Assets, N.A. | Conversion (New York trust) | Dec 12, 2025 | Conditional | | | Paxos | Paxos Trust Company, N.A. | Conversion (NYDFS trust) | Dec 12, 2025 | Conditional | | | [[Stripe]] (Bridge) | Bridge National Trust Bank | De novo trust | Feb 12, 2026 (CD 1365) | Conditional | $45M Tier 1; must conform to the GENIUS Act | | Protego | National Digital Trust Company | De novo trust (second attempt) | Feb 13, 2026 (CD 1366) | Conditional | **The approval ICBA's lawsuit asks a court to vacate** | | [[Crypto.com]] | Foris DAX National Trust Bank | De novo trust | Feb 20, 2026 (CD 1367) | Conditional | ⚠️ Foris DAX reportedly gave $10M (Oct 2025) and $5M (Jan 2026) to [[MAGA Inc]] (American Banker) | | [[Coinbase]] | Coinbase National Trust Company | De novo trust | Apr 2, 2026 (CD 1370) | Conditional | $60M Tier 1; will not issue stablecoins | | Laser Digital (Nomura) | Laser Digital National Trust Bank | De novo trust | May 29, 2026 (CD 1377) | Conditional | | | [[Morgan Stanley]] | Morgan Stanley Digital Trust, N.A. | De novo trust | Jun 18, 2026 (CD 1378) | Conditional | Wall Street incumbent entering custody and staking | | Sony Bank | Connectia Trust, N.A. | De novo trust | Jul 2, 2026 (CD 1380) | Conditional | USD stablecoin, launch planned 2027 | | **[[World Liberty Financial]]** | World Liberty Trust Company, N.A. | De novo trust | **Aug 14, 2026 (CD 1385)** | Conditional | **Trump family.** $20M Tier 1; no deposits; ⚠️ may not issue, custody or deal in WLF tokens; passivity commitments from [[Eric Trump]], StringZ's manager and [[Zak Folkman]]. 221-day review | | Bastion | Bastion national trust | Conversion (NYDFS trust) | Sep 18, 2026 | Conditional | Sony's stablecoin partner | | Agora | Agora National Trust Bank | De novo trust | Sep 18, 2026 | Conditional | AUSD stablecoin | | Catena Labs | Catena Trust Bank | De novo trust | Sep 18, 2026 | Conditional | "AI-native" bank from a Circle co-founder | ### Crypto-adjacent and fintech full-service banks | Company | Entity | Conditional approval | Status | Notable | |---|---|---|---|---| | **[[Erebor]]** | Erebor Bank, N.A. | **Oct 15, 2025** (OCC NR 2025-101) | **Open Feb 8, 2026** | First de novo of Gould's tenure, approved in 4 months; 12% leverage condition for 3 years; Luckey/Lonsdale/Thiel. See [[Erebor Dossier]] | | Nubank | U.S. national bank | announced Jan 29, 2026 | Conditional | Exact decision date not verified | | VALT | VALT Bank, N.A. | Mar 13, 2026 (CD 1368) | Conditional | | | Mercury | Mercury Bank, N.A. | Apr 24, 2026 (CD 1372) | Conditional | $300M capital | | Augustus | Augustus National Bank, N.A. | May 8, 2026 (CD 1374) | Conditional; FDIC approved Aug 4 | Plans a stablecoin subsidiary | | Upstart | Upstart Bank, N.A. | announced Jul 23, 2026 | Conditional | | | Revolut | Revolut Bank US, N.A. | ⚠️ Sep 2, 2026 | Conditional | Still needs FDIC and Fed approval | | OpenReserve | OpenReserve Bank | Sep 2, 2026 | Conditional | Andreessen Horowitz–backed "onchain" bank; $210M capital, 12% leverage | | Mission Lane | Mission Lane Bank, N.A. | ~Sep 25, 2026 | Conditional | Credit-card bank | ### Denials and returns | Company | Outcome | Date | Stated reasons | |---|---|---|---| | Wise | **Denied** (trust charter) | ~Jul 21, 2026 (CD 1381) | Anti-money-laundering and state enforcement history; lack of fiduciary experience. First denial of the wave | | Zerohash | **Returned** as materially deficient | Jul 17, 2026 | Refiled by Aug 27, 2026 | | bunq | **Denied** (national bank) | Aug 4, 2026 (CD 1384) | Capital source, management, profitability, "character and fitness" | ### Pending (publicly reported) Payoneer (filed Feb 24, 2026), Kraken (Payward National Trust Company, filed May 8, 2026), Block (Builders Bank & Trust, filed Sep 8, 2026), and ⚠️ per American Banker's tracker only: Lorum, EDX Trust, Dakota, Zaria, Stark Bank, a CBW Bank conversion and Avant. **Related, not charters:** the OCC let **SoFi Bank** set up a subsidiary to issue and redeem payment stablecoins (letter dated Jul 23, 2026), and approved Bhavin Turakhia's purchase of the First National Bank of Lacon, Illinois (Mar 23, 2026). ## The rules that made the wave possible - **IL 1183 (Mar 7, 2025)** and **IL 1184 (May 7, 2025)**, both before Gould under Acting Comptroller Rodney Hood: reaffirmed that banks may custody crypto, issue stablecoins and buy or sell crypto for customers, and dropped the requirement to get supervisory sign-off first. - **IL 1186 (Nov 18, 2025):** banks may hold crypto to pay network fees. **IL 1188 (Dec 9, 2025):** riskless-principal crypto trades are permissible. - **The trust-bank rule (12 CFR 5.20):** proposed Jan 8, 2026, final Feb 27, effective Apr 1, 2026. It replaced the requirement that a national trust bank conduct "fiduciary activities" with "operations of a trust company and activities related thereto." This is the change that lets a stablecoin company qualify for a trust charter, and the one ICBA is suing over. - **The [[GENIUS Act]]** (July 2025) and the OCC's proposed implementing rule (Feb 25, 2026) made a federally chartered trust bank a natural home for a payment-stablecoin issuer. Gould himself helped lay the foundation: **IL 1176 (Jan 11, 2021)**, which ICBA's suit also challenges, was issued while he was the OCC's chief counsel in the first Trump administration. ## Pushback - **Bank trade groups.** The ABA and four other associations asked the OCC on Jul 18, 2025 to postpone the Circle, Ripple and Fidelity applications. The Bank Policy Institute opposed Coinbase (Nov 3, 2025) and BitGo (Nov 7, 2025). The Independent Community Bankers of America (ICBA) opposed Protego, Crypto.com and the December batch, and in January 2026 asked the OCC to freeze pending applications until the rule was final. - **The lawsuit.** On **October 2, 2026**, ICBA sued the OCC in federal district court in Washington, D.C. (No. 1:26-cv-03441) under the Administrative Procedure Act. It challenges the trust-bank rule and IL 1176, and asks the court to vacate the Protego approval. If it succeeds on the rule, every trust charter granted under it is exposed, World Liberty's included. The OCC declined to comment. - **Congress.** [[Elizabeth Warren]] asked Gould on Jan 13, 2026 to halt the WLF review until the president divests; he declined about Jan 23. She wrote about Erebor on Feb 26 and Apr 23, 2026. After the WLF approval she and colleagues introduced the Ending Presidential Corruption in Banking Act (Aug 15, 2026). The minority party can write letters and bills but cannot stop a charter. - **Advocacy groups.** The National Community Reinvestment Coalition opposed Coinbase (Apr 9, 2026); Americans for Financial Reform opposed WLF. ## Was World Liberty's charter a favor? What the baseline shows The charter file's standing question (see [[World Liberty Trust OCC Bank Charter Approval]]) is whether WLF got special treatment. Set against the full wave: - **It was not faster.** Bloomberg's analysis puts the median review under Gould at **126 days** (176 before him). WLF took **221 days**, the slowest crypto approval of the wave and nearly double Gould's advertised 120-day target. - **Its conditions are not lighter.** $20M of Tier 1 capital sits within the range for trust charters (Agora and Catena $10M, Crypto.com and Protego $15M, Bridge $45M, Coinbase and Sony $60M). WLF also carries conditions no one else has: it may not touch its own tokens, and three owners, including the president's son and the UAE investor's manager, signed passivity commitments. - **The favor is not in the decision; it is in the category.** The decisive steps were upstream and generic: the GENIUS Act, the trust-bank rule rewrite, and an OCC that approves almost everything. WLF got the same deal as everyone else. That deal did not exist two years ago, and the president's family was positioned to use it from the start. - **The live risk is supervision.** Once open, World Liberty Trust will be examined by an agency headed by the president's appointee. Examination findings are confidential. That cannot be tested from outside. Erebor is the opposite case. It was **faster** than the baseline: the first de novo of Gould's tenure, approved in four months, after its investor memo promised a charter "in less than 6 months" and pointed to the founders' political network and a co-founder's "unique" connections to the Comptroller. If any charter in the wave shows a timing advantage, it is Erebor's, not WLF's. ## Watch - **ICBA v. OCC** (D.D.C. 1:26-cv-03441): any ruling on the trust-bank rule reaches every trust charter granted under it. - **Final approvals and openings**, especially World Liberty Trust (18-month window from Aug 14, 2026) and Ripple, Paxos and Fidelity. - **Change-in-control review** of StringZ Holding RSC's 49% of WLF's bank holding company. - **The next denial.** Two denials and one return so far. Whether any politically connected applicant is ever turned down is the real test of the baseline. - **Midterms (Nov 3, 2026).** A Democratic Senate would make Warren the likely Banking Committee chair, with subpoena power over Erebor's and WLF's charter files. ## See Also - [[OCC]] · [[Jonathan Gould]] · [[FDIC]] - [[Erebor]] · [[Erebor Dossier]] · [[World Liberty Financial]] · [[World Liberty Trust OCC Bank Charter Approval]] - [[GENIUS Act]] · [[Stablecoin]] · [[Regulatory Capture]] - [[Fintech Sector]] · [[Cryptocurrency Sector]] · [[Crypto-Political Machine]] - [[Companies Watchlist Hub]]