A national trust bank charter has become the most contested route into the US banking system for fintech and crypto firms. On 26 October 2026 the Office of the Comptroller of the Currency (OCC) gave Ripple final approval to open Ripple National Trust Bank, days after spend-management company Ramp filed its own application, and while a community bank trade group is suing the OCC to stop the trend.
The charter lets a company operate as a federally supervised national bank without taking deposits or making commercial loans. That limited scope is exactly why fintechs want it, and exactly why incumbent banks object to it. This explainer sets out what the charter permits, what changed in the OCC’s rules this year, and what the legal challenge could mean for applicants.
What a national trust bank charter actually allows
A national trust bank is a national bank whose operations are limited to those of a trust company and related activities. It is chartered and supervised by the OCC, the same federal regulator that oversees full-service national banks, but it does not run the deposit-taking and lending business that defines a commercial bank.
In February 2026 the OCC finalised a rule that sets out the scope of these institutions. According to OCC Bulletin 2026-4, published on 27 February 2026, the rule clarifies “the longstanding authority of national banks limited to the operations of trust companies and activities related thereto to engage in non-fiduciary activities in addition to their fiduciary activities.” The rule took effect on 1 April 2026.
The wording change that matters
The final rule amends the OCC’s chartering regulation at 12 CFR 5.20. Its key edit replaces references to “fiduciary activities” with the phrase “operations of a trust company and activities related thereto.” The OCC states that the rule “would neither expand nor contract” its authority to charter a national bank, and that it applies to every applicant for a charter limited to trust company operations.
In practice, the change confirms that a trust bank is not confined to acting as a fiduciary. It can also carry out related non-fiduciary work such as custody and safekeeping, which is the service most fintech and digital asset applicants want to offer.
Why fintechs are applying for an OCC trust charter now
For most US fintechs, the alternatives are slow or indirect. A company can partner with a sponsor bank, collect state money transmitter licences one jurisdiction at a time, or pursue a full bank or industrial loan company charter, which brings deposit insurance and a heavier supervisory load. A national trust bank charter offers a single federal regulator for a defined set of activities.
Ramp’s stated rationale reflects that. In posts announcing its application, reported by Banking Dive on 20 October 2026, the company said the proposed trust bank “would bring these services under a consistent federal regulatory framework, helping us build great products alongside our banking partners.” Ramp said it would offer fiduciary investment management and digital asset custody, and would not take deposits or make commercial loans.
The filing came a day after Ramp announced a $1.85 billion funding round led by Dragoneer Investment Group, which valued the company at $60 billion, according to the same report.
Ramp and Ripple: two national trust bank models compared
The two most recent cases show how differently companies plan to use the charter.
| Item | Ripple National Trust Bank | Ramp (proposed) |
|---|---|---|
| OCC status | Final approval, 26 October 2026, after conditional approval in December 2025 | Application filed in October 2026 |
| Core activities | Managing segregated reserves for the RLUSD stablecoin, acting as collateral trustee for RLUSD holders, fiduciary digital asset custody | Fiduciary investment management and digital asset custody |
| Deposits and commercial loans | Not part of the approved activities described by Ripple | Ramp says it will not take deposits or make commercial loans |
| Relationship to existing licences | RLUSD continues to be issued by Ripple’s NYDFS-regulated limited purpose trust company | Ramp says it will keep building products with its banking partners |
In its 26 October announcement, Ripple said RLUSD will still be issued by Standard Custody & Trust Company, its New York Department of Financial Services-regulated limited purpose trust company, with the national trust bank adding OCC supervision to the reserve structure. Ripple said RLUSD, launched in December 2024, has reached a $2.5 billion market capitalisation, with BNY as primary reserve custodian. Ripple also said it will work with regulators as the US implements the framework set by the GENIUS Act.
The ICBA lawsuit puts the trust charter model under legal challenge
The Independent Community Bankers of America (ICBA) sued the OCC on 2 October 2026, according to Banking Dive. The trade group argues that the surge in applications and approvals is creating “a gaping hole in financial regulation” and that the OCC’s posture allows firms engaged in “highly risky cryptocurrency and digital assets activities” to enter the banking system under “lightly regulated national charters”.
The ICBA said the OCC has approved or conditionally approved 21 national trust bank charters since the start of President Donald Trump’s second term, 13 of them for crypto companies. Its central legal claim is that “there is no statutory basis for the OCC’s position that it can charter crypto trust banks that are neither depository nor fiduciary.”
The regulator’s position
Comptroller of the Currency Jonathan Gould has defended the approvals. Speaking in May, he said: “we don’t have a zero risk tolerance anymore,” adding that the statute “talks about a reasonable chance of success. That’s how we evaluate applications.” Ji Hun Kim, chief executive of the Crypto Council for Innovation, called the ICBA suit “a clear attempt to resist national trust charters, payments innovation, and competition in financial services.”
What applicants should watch before filing
The OCC’s February rule gives applicants a clearer legal basis for combining fiduciary and non-fiduciary services, but it does not settle the dispute. The ICBA’s case targets precisely the line the rule draws: whether a trust bank can conduct activities that are neither deposit-taking nor fiduciary. A ruling against the OCC could narrow what new charters may include, or force applicants to show a larger fiduciary component in their business plans.
- Business plan scope: the OCC reviews whether every proposed activity fits “operations of a trust company and activities related thereto”. Custody, trustee and investment management services sit most comfortably within that phrase.
- Two-stage approval: Ripple’s path ran from conditional approval in December 2025 to final approval in October 2026, so firms should plan for an organisation phase before opening.
- Existing licences stay relevant: Ripple kept its New York trust company as RLUSD issuer, which suggests a federal trust charter often sits alongside, rather than replaces, state licences.
National trust bank charter FAQs
Can a national trust bank take deposits or make loans?
Not in the way a commercial bank does. Ramp has said its proposed trust bank would not take deposits or make commercial loans, and Ripple’s approved activities centre on reserve management, collateral trusteeship and custody. Firms that need to hold insured deposits generally have to look at a full bank or industrial loan company charter instead.
What did the OCC’s 2026 chartering rule change?
The final rule, announced in OCC Bulletin 2026-4 on 27 February 2026 and effective 1 April 2026, amended 12 CFR 5.20. It replaced references to “fiduciary activities” with “operations of a trust company and activities related thereto”, confirming that national trust banks may conduct non-fiduciary activities alongside fiduciary ones. The OCC said the rule neither expands nor contracts its chartering authority.
How many national trust bank charters has the OCC approved recently?
According to the ICBA’s lawsuit, as reported by Banking Dive, the OCC has approved or conditionally approved 21 national trust bank charters since the start of President Trump’s second term. The ICBA says 13 of those went to crypto companies. The figure comes from the trade group, not from an OCC publication.
Does a national trust charter replace state licences?
Not necessarily. Ripple’s RLUSD stablecoin will continue to be issued by its New York-regulated limited purpose trust company, with the national trust bank adding federal supervision over reserves and custody. Companies should map which activities sit in which entity before assuming one charter covers the whole business.
What happens to pending applications if the ICBA wins its lawsuit?
The outcome is not yet known. The ICBA argues the OCC has no statutory basis to charter crypto trust banks that are neither depository nor fiduciary, so a ruling in its favour could restrict the non-fiduciary activities new charters may include. Applicants with plans built mainly on fiduciary custody and trustee services are less exposed to that argument.
For fintechs, the national trust bank charter is now a realistic way to bring custody, stablecoin reserve management and investment services under one federal supervisor without becoming a deposit-taking bank. For community banks, it is a competitive threat they are contesting in court. Until that case is resolved, applicants should design business plans that fit squarely within trust company operations. For related coverage, see how US banks are expanding into digital asset custody and why Chime chose to buy the bank behind it.
