OCC grants conditional federal trust approvals to three crypto firms

On Sept. 18 the Office of the Comptroller of the Currency issued conditional federal trust approvals for three firms focused on stablecoins and custody. Agora and Catena received preliminary authorization to organize as de novo national trust banks. Bastion received conditional approval to convert its New York trust charter to a national trust company. Each firm must complete pre-opening conditions and obtain final permission before operating under a federal charter.

The OCC applied a common regulatory framework to the three decisions. All must limit activities to trust-company functions and related services, avoid classification as a bank under the Bank Holding Company Act and notify the OCC before making significant business-plan changes. The OCC’s letters state Agora and Bastion will not take FDIC-insured deposits and note that Catena cannot represent payment stablecoins as FDIC-insured.

Capital and liquidity requirements differ by applicant. Agora and Catena must maintain at least $10 million in tier 1 capital and hold the greater of 50% of tier 1 capital or $5 million in eligible liquid assets. Bastion must maintain at least $6 million in tier 1 capital and the greater of 50% of tier 1 capital or $3 million in eligible liquid assets. Each firm must reassess capital and liquidity quarterly and increase holdings if risk profiles require it.

All three must also keep eligible liquid assets equal to 180 days of operating expenses to support a distressed wind-down during their first three years under a federal charter. The OCC specified that those wind-down assets cannot be double-counted toward the liquidity calculated for capital requirements.

Timing and procedural conditions were set in the approvals. Agora and Catena must notify OCC chartering staff at least 60 days before a planned opening. Their preliminary approvals expire if they fail to raise required capital within 12 months or fail to open within 18 months. Bastion’s conversion approval terminates automatically if the conversion is not completed within six months unless the OCC grants an extension for extenuating circumstances. Each approval includes conditions on compliance programs, audits, information security and governance.

The three firms described different business plans in their filings. Agora plans dollar-backed stablecoin issuance, reserve management, digital-asset custody, custody-linked payments and investment advice for institutional and business custody clients, and intends to shift issuance of AUSD from an offshore entity to the proposed national trust bank after transfer of assets. Catena proposed fiduciary and non-fiduciary custody, fiduciary investment management and trust services, along with conversion, clearing and execution services tied to assets it holds in custody. Bastion’s conversion filing focuses on custodial wallets, conversion services for custody customers, white-label stablecoin issuance and technology services for other authorized issuers, with third parties potentially remaining issuer of record.

The Sept. 18 decisions are part of broader OCC activity on digital-asset trust charters. OCC records indicate about 23 of roughly 40 new-charter applications over an 18-month span involved digital assets, according to Comptroller Jonathan Gould. The agency’s 2026 trust-bank rule, effective April 1, clarified that national trust banks may perform permitted non-fiduciary activities alongside fiduciary services, and the OCC continues to assess statutory authority on a case-by-case basis.

Regulatory developments remain unsettled at the federal and state levels. Proposed implementing rules under the GENIUS Act, which would set reserve, capital and liquidity expectations for federal stablecoin issuers, remained proposed as of Sept. 22. State regulators, including the Conference of State Bank Supervisors, have questioned the scope of the OCC’s trust-charter approach and discussed potential legal challenges if charters are judged to exceed the National Bank Act.

The OCC’s letters leave final approvals, conversions, reserve arrangements and operational readiness as outstanding requirements before any of the three firms may begin operating under a federal charter.