The Independent Community Bankers of America called the Office of the Comptroller of the Currency’s conditional approval of Coinbase’s national trust charter a grave mistake on April 2, 2026, warning that the decision exposes U.S. consumers to new risks as crypto firms push deeper into federally chartered banking structures.
The OCC granted conditional approval to Coinbase National Trust Company on April 2, 2026, roughly six months after the application was filed on October 3, 2025. The approval marks one of the most significant regulatory milestones for a publicly traded crypto company seeking a federal charter.
What Triggered ICBA’s Objection to the Approval
ICBA wasted no time responding. In a statement released the same day as the approval, the trade group representing community banks said the application fails to meet the National Bank Act and the OCC’s own regulations.
The group cited specific deficiencies in risk and control functions, profitability projections, and resolution planning. ICBA also repeated its broader challenge to the OCC’s authority to use the national trust bank chartering framework for crypto firms.
ICBA’s position is that the OCC should not be expanding non-fiduciary crypto activities through the trust charter pathway without the prudential safeguards that apply to insured depository institutions. Community banks see the approval as a precedent that could allow crypto firms to operate under lighter regulatory scrutiny than traditional banks face.
What the Trust Charter Would Actually Allow
The controversy hinges partly on a widespread misunderstanding. Coinbase is not becoming a commercial bank. The proposed entity, Coinbase National Trust Company, is described in the public OCC application as a non-insured national trust company and a direct, wholly owned subsidiary of Coinbase Global.
Coinbase stated on April 2 that the charter does not make it a commercial bank and that it will not take retail deposits or engage in fractional reserve banking. The distinction matters: a trust charter is narrower in scope than a full banking license.
According to the application, the entity would expand Coinbase’s institutional custody business while maintaining integrations for staking, financing, and trading through affiliates. The filing also noted plans to explore payments products. As regulatory clarity around digital assets continues to evolve, similar to the shifting institutional stance seen in Vanguard’s reversal on Bitcoin ETFs, the trust charter represents another step toward traditional financial infrastructure for crypto.
Why This Fight Matters Beyond Coinbase
The scale of Coinbase’s custody operation underscores the stakes. The OCC application disclosed that Coinbase held $245.7 billion in assets under custody as of June 30, 2025, representing approximately 7% of total crypto market capitalization at that date.
That figure makes Coinbase one of the largest custodians in the digital asset space. A federal trust charter would give the company a unified national regulatory framework instead of the current patchwork of state-by-state trust licenses, a structural advantage that community banks view as a competitive threat enabled by ongoing shifts in how regulators approach crypto firms.
ICBA’s objection is not just about Coinbase. The trade group argues that if the OCC can grant trust charters to crypto companies without requiring the full prudential regime applied to insured banks, the precedent weakens the regulatory perimeter that separates banking from other financial activities. Community banks already compete against larger institutions with scale advantages; adding federally chartered crypto custodians to the landscape intensifies that pressure.
The full OCC conditional approval letter, which would detail the specific pre-opening conditions Coinbase must satisfy, has not been publicly released. The known facts are drawn from the OCC’s Corporate Applications Search status page, Coinbase’s public statement, and ICBA’s response.
The dispute arrives at a moment when the boundaries between traditional finance and digital assets are being actively renegotiated across multiple fronts. Whether the OCC’s trust charter framework can bear the weight of large-scale crypto custody operations, or whether it needs the additional guardrails ICBA demands, is a question that will likely extend well beyond this single application.
Disclaimer: This article is for informational purposes only and does not constitute financial or investment advice. Cryptocurrency and digital asset markets carry significant risk. Always do your own research before making decisions.
