While markets obsess over crypto prices, Wall Street giants and native crypto firms are competing for trust bank charters from the OCC. Circle, Ripple, BitGo, Fidelity, Paxos, Crypto.com, and even Morgan Stanley have joined the queue. The trend echoes the 1960s Wall Street paperwork crisis: surging trading volumes clogged back offices, forcing markets to close every Wednesday for six months. The solution came in 1973 with the Depository Trust Company (DTC), which digitized record-keeping. Today, DTC holds over 140 million securities worth $87.1 trillion.
Private keys as 'paper': The core pain point
In crypto, the 'paper' is the private key—whoever holds it controls the asset. This poses familiar challenges: operational control, asset segregation, auditability, bankruptcy concerns, and permanent loss if keys are lost. Trust bank charters are emerging as the new trust mechanism. Since late 2025, the Office of the Comptroller of the Currency (OCC) has accelerated approvals. On December 12, 2025, it conditionally approved five applications: Circle's First National Digital Currency Bank, Ripple National Trust, and conversions for BitGo, Fidelity Digital Assets, and Paxos. In February 2026, Stripe's crypto arm Bridge and Crypto.com received preliminary nods. Last week, Morgan Stanley filed to create Morgan Stanley Digital Trust National Association.
These national trust banks cannot take deposits or make loans; they lack FDIC insurance. They offer only custody, safekeeping, and trust administration—essentially bookkeeping for crypto assets.
Why now? Regulatory clarity and market structure
The rush follows recent OCC clarifications. In May 2025, the OCC confirmed national banks can buy or sell custodied assets at customer direction. In December 2025, it allowed 'riskless principal' crypto transactions via intermediaries. On February 27, 2026, the OCC clarified that from April 1, 2026, national trust banks can engage in non-fiduciary activities beyond narrow trust duties. This opens new value chains for custody, settlement, and reserve management.
Legislation also matters. In July 2025, President Trump signed the GENIUS Act, creating a federal framework for payment stablecoins. Both Bridge and Circle cited plans to operate stablecoin and reserve businesses under this framework.
On the market side, institutional investment has shifted to vehicles like ETFs, funds, and managed accounts that require compliant custodians. In April 2025, BlackRock added Anchorage Digital Bank as a Bitcoin custodian for its iShares Bitcoin Trust. Morgan Stanley's digital asset strategy head Amy Oldenburg hinted at involvement during a recent fireside chat.
The economics: Backdoor or necessary evolution?
Custody fees alone are modest—Coinbase no longer breaks them out separately. But the associated services generate recurring revenue. The global securities lending income hit $153 billion in 2025. State Street reported $13.94 billion in total revenue for 2025, with service fees (custody, accounting, fund administration) accounting for about 40%. Critics warn these charters could become a 'backdoor' into banking without deposit-taking or public obligations. Yet regulatory change is underway: the OCC's conditional approvals signal that crypto assets have reached sufficient scale to require institutional-grade back-office operations. This is less a crypto phenomenon and more a natural evolution as market participants seek to solve inefficiencies.