Coinbase National Trust Company’s federal custody charter has taken effect, advancing the exchange’s institutional custody expansion past the preliminary approval stage. The Office of the Comptroller of the Currency (OCC) application register lists November 6 as the effective date, and a final conditional approval letter dated the same day confirms the bank satisfied its pre-opening requirements, authorizing it to commence operations on November 9.
The charter grants the new entity permission to provide cryptocurrency custody under federal fiduciary supervision. The OCC has also approved an arrangement to transition accounts from Coinbase’s New York trust company over time. Coinbase announced the final approval on November 9, stating the charter would establish a consistent federal framework for its custody business. The milestone follows the preliminary conditional approval granted on April 2.
THE CHARTER PATH / 2026APRIL 2Preliminary approvalOrganizing the bankNOVEMBER 6Charter effectiveFinal conditions applyNOVEMBER 9Opening authorizedPermission to commenceSequence only; spacing does not measure elapsed time.
THE CHARTER PATH / 2026APRIL 2Preliminary approvalOrganizing the bankNOVEMBER 6Charter effectiveFinal conditions applyNOVEMBER 9Opening authorizedPermission to commenceSequence only; spacing is not elapsed time.
Explore what the authorization changes
Explore what the authorization changesCustody authorityAccount transfer
OCC authorization brings fiduciary custody into the national trust company’s permitted scope.
OCCAuthorizes fiduciary custodyCoinbase National Trust CompanyFiduciary crypto custodyFiduciary dutiesTrust-company limitsOCCAuthorizescustodyCoinbase NationalTrust CompanyFiduciary crypto custodyFiduciarydutiesTrust-companylimits
The September 1 agreement provides for a gradual transfer from the New York trust company to the national trust company.
Coinbase CustodyTrust CompanyCoinbase NationalTrust CompanySept. 1 agreementPlanned over timeApril plan: entire custody business over a three-year initial periodCoinbase CustodyTrust CompanySept. 1 agreementPlannedover timeCoinbase NationalTrust CompanyApril plan: entire business overa three-year initial period
Individual account completion remains undisclosed.
The dates mark legal milestones, not a verified operating launch. The three-year migration horizon is the April plan.
The OCC’s final approval permits cryptocurrency custody in a fiduciary capacity, subjecting the national trust company’s custody services to fiduciary duties and standards of conduct. The approval letter also discloses a September 1 agreement between Coinbase Custody Trust Company and the new national bank providing for a gradual transition of custody-service rights and responsibilities from the New York trust company to the national trust company. The OCC approved the acquisition and assumption of those accounts and assets under an exemption from certain restrictions on transactions between banks and affiliates.
The final letter describes an intention to begin migration, though Coinbase’s November 9 announcement provides no completed-transfer figures or client-by-client schedule. The April plan envisioned moving the entire custody business over the national bank’s three-year initial operating period.
The November conditions supersede those imposed in April and restrict the bank to trust-company operations and related activities outlined in its business plan. During its first three operating years, significant deviations require 60 days’ prior notice and written OCC non-objection. The final letter specifically includes material changes to products and services and any offering of transactional services for custody-account customers.
The bank must also maintain at least $60 million in Tier 1 capital, prescribed liquid-asset buffers, and a separate reserve covering 180 days of operating expenses during that period. The April decision described an uninsured institution, and the final approval preserves the limited trust-company scope.