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- Coinbase secured OCC final approval to operate Coinbase National Trust Company.
- The federal charter took effect on Nov. 6 before Coinbase's announcement.
- A transition plan moves existing New York custody business over 3 years.
Coinbase has received final approval from the Office of the Comptroller of the Currency (OCC) to operate Coinbase National Trust Company, giving its institutional custody business a federally supervised entity.
The charter took effect on Nov. 6, three days before Coinbase’s Nov. 9 announcement. A transition plan calls for moving its existing New York custody business into the new company over its first three years.
Final Approval Moves the Trust Company Beyond April’s Conditions
Coinbase applied for the charter on Oct. 3, 2025, and received preliminary conditional approval on April 2. At that stage, it still needed to meet preopening requirements before receiving authorization to begin business.
Those requirements included an independent external auditor and financial statements prepared under U.S. generally accepted accounting principles.
The OCC’s application record now marks the charter as effective. It lists the New York-based company under charter number 25390, approved as a wholly owned subsidiary of Coinbase Global.
For custody customers, the change creates a federal entity authorized to safeguard digital assets and handle related transactions. Coinbase described the regulatory shift as:
“[…] bringing Coinbase National Trust Company’s trust activities into a consistent federal regulatory framework […].”
The company has operated Coinbase Custody Trust Company under a New York limited-purpose trust charter since 2018. The new federal trust company builds on that business, with the OCC taking responsibility for supervising the new entity’s permitted activities.
Existing Custody Business Is Set for a Three-Year Transition
Coinbase’s migration plan covers the custody business currently housed in Coinbase Custody Trust Company, which is supervised by the New York State Department of Financial Services.
The three-year timetable appears in the OCC’s April approval. However, the Nov. 9 announcement does not give a client-by-client transfer schedule or explain which customers will move first.
The charter application outlined two custody arrangements. Prime Vault uses blockchain addresses dedicated to each customer, while Prime Custody uses shared operational wallets to support trading and settlement within custody.
Coinbase says Prime Custody client assets are legally segregated from the company’s assets and from each other, even when held in shared wallets.
Coinbase, Inc., the exchange entity, remains under New York’s financial regulator. In April, Coinbase said its BitLicense and existing state trust charter would remain in place.
Trading and Financing Services Stay With Coinbase Affiliates
The trust company’s approved activities include accepting, holding and transferring clients’ digital assets and custodial cash. Cash held in custody is to be placed in accounts at third-party banks for customers’ benefit.
Customers can also access staking, Prime Trading and Prime Financing through other Coinbase entities. The national trust company facilitates that access, while the affiliates provide the underlying services.
Its current Prime Custody setup uses Coinbase, Inc. for order routing and separate Coinbase credit entities for lending and margin products.
Coinbase’s application also identified digital-asset payments and custody features connecting clients to selected smart contracts as areas to explore. The Nov. 9 announcement does not introduce a named new payments product or a separate launch timetable for those services.
The Charter Does Not Turn Coinbase Into a Retail Bank
When Coinbase received conditional approval in April, Coinbase Institutional co-CEO Greg Tusar made the intended limits clear:
“Coinbase is not becoming a commercial bank. We will not be taking retail deposits. We will not be engaging in fractional reserve banking.”
The national trust company is not insured by the Federal Deposit Insurance Corporation (FDIC). Its custody work is subject to fiduciary duties, meaning it owes legal obligations to the clients whose assets it holds.
The OCC’s April conditions required at least $60 million in tier 1 capital, alongside liquid assets covering 180 days of operating expenses. Those requirements apply to the trust company’s own financial resources.
At least half of that capital, or $30 million if greater, must be held in eligible liquid assets. The operating-expense reserve is separate.
