Model OCC Charter Applicant Preset:
Charter Context: Jack Dorsey's Block joins Coinbase, Ripple, and Circle in seeking Office of the Comptroller of the Currency (OCC) approval for a National Trust Bank charter. Unlike full commercial charters, trust banks operate under strict Tier-1 fiduciary reserve baselines, 100% asset segregation, and heightened operational solvency tests for $BTC and stablecoins.
OCC National Trust Applicants
Updated Q1 2026 Filings
| Applicant | Core Assets | Charter Status | Primary Supervison |
|---|---|---|---|
|
Block
|
BTC, Stablecoins | Filed / Active | OCC / Fed Board |
|
Coinbase
|
Multi-Crypto, USDC | Under OCC Review | OCC Trust Div. |
|
Ripple
|
RLUSD, XRP, BTC | OCC Prelim. Phase | OCC / NYDFS Recip. |
|
Circle
|
USDC Cash Reserves | Hearing Prepared | OCC Federal Trust |
Statutory 12 U.S.C. § 27 Trust Standards
Segregated Custodial Wallets: Zero co-mingling of on-chain fiduciary assets with proprietary balance sheets.
Fedwire Direct Master Account: Direct reserve clearing without third-party correspondent partner bank choke-points.
Pre-funded Operating Capital: Continuous maintenance of 36-month operating liquidity buffer independent of market volatility.
Custody Reserve Stress Simulator
Real-Time OCC Adequacy Model
$250M
Equity capital deposited with the Federal Reserve to back custody operations.
$12.0B
Aggregated $BTC, ETH, and compliant reserve stablecoins in fiduciary custody.
15%
OCC-mandated stress test assessing crypto market contraction on fiduciary liquidity.
105%
Statutory target buffer for uninsured fiduciary institutions.
Fully Compliant Reserve Structure
Min. Capital Required
$180M
OCC Basel Tier-1 Base
Excess Capital Buffer
+$70M
Capital Safety Margin
Readiness Score
88%
OCC Approval Likelihood
Effective Solvency
138.9%
Stress Adjusted Coverage
Regulatory Adequacy Scale
Optimal Safety Buffer
OCC National Trust Bank Approval Lifecycle (12 CFR Part 5)
Statutory Federal Timeline
1
Charter Filing & Notice
Formal submission to the Comptroller of the Currency with public notice and 30-day comment window.
2
Capital Adequacy Audit
In-depth OCC examination of Tier-1 capital pledges, custodial custody architectures, and BSA/AML safeguards.
3
Conditional Approval
Comptroller grants conditional status requiring final operational drill tests and Federal Reserve connection.
4
Full Federal Charter
Final certificate of authority issued; bank commences nationwide crypto fiduciary custody & settlement.
Audit Brief Preview
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