Competition intensifies in the pursuit of U.S. banking charters
Fintech companies in the cross-border payments space are increasingly turning to the United States and specifically national trust bank charters as a means to streamline their operations and gain access to critical American financial infrastructure. These charters, issued by the Office of the Comptroller of the Currency (OCC), offer a single federal regulator and simplified regulatory requirements compared to navigating state-by-state money transmitter licenses.
Applying for a National Trust Bank Charter
To acquire a national trust bank charter, fintechs must submit detailed applications to the OCC. Notable applicants include Wise (formerly TransferWise), which applied in June 2025, and crypto-related firms like Circle, Ripple, and Fidelity Digital Assets [1][2]. The public portion of Wise's application is accessible through the OCC's FOIA reading room.
Operational Advantages of National Trust Bank Charters
A national trust bank charter offers several operational advantages to fintechs. These include:
- Operating under comprehensive federal oversight by the OCC instead of multiple state regulators.
- Providing fiduciary or custodial services, such as stablecoin issuance or custody, without needing separate money transmission licenses (MTLs) in almost all states.
- Access to crucial U.S. payment infrastructure, including the possibility of obtaining a Fed master account to directly connect to Federal Reserve payment systems and clear U.S. dollar-based transactions [1][3].
Limitations of National Trust Charters
National trust banks differ from traditional banks in several ways. They are typically uninsured institutions, meaning they do not hold FDIC insurance. Additionally, national trust banks cannot take traditional deposits or make loans. Moreover, obtaining a Fed master account involves a more rigorous tiered review process by the Federal Reserve [1][5].
Evolving Regulatory Landscape
The OCC's adoption of national trust bank charters for fintechs reflects an evolving regulatory framework aimed at integrating innovative payment and crypto companies into the regulated banking system. This integration facilitates scalability and compliance at institutional levels while managing risk [2][3].
Potential Benefits and Challenges
Obtaining a national trust bank charter could potentially allow companies to scale up more quickly and comply with a single set of regulations. Companies with these charters gain access to crucial money movement systems in the US, such as Fedwire, ACH, and RTP. They can also settle transactions in USD, the world's global reserve currency. However, these entities remain uninsured, and gaining Fed master account access involves stringent review [1][2][3][5].
Ripple is currently seeking access to the Federal Reserve's payments infrastructure through one of its subsidiaries. It's worth noting that Moneycorp has been approved for a state-level Innovation Bank Charter from the Connecticut Department of Banking.
As the demand for seamless payments grows, we can expect more companies to follow suit and apply for US banking charters this year. The benefits of national trust bank charters for fintechs in cross-border payments are undeniable, making them an attractive option for companies looking to expand their reach and improve their operations.
[1] Office of the Comptroller of the Currency. (n.d.). National Trust Bank Charter. Retrieved from https://www.occ.gov/topics/chartering-and-licensing/national-trust-banks/ [2] Office of the Comptroller of the Currency. (2021, October 7). OCC's National Trust Bank Charter for Innovation. Retrieved from https://www.occ.gov/news-events/news-releases/2021/nr-occ-2021-122a.html [3] Office of the Comptroller of the Currency. (2021, December 2). OCC Issues National Trust Bank Charter to Anchorage Digital Bank, N.A. Retrieved from https://www.occ.gov/news-events/news-releases/2021/nr-occ-2021-189a.html [4] Office of the Comptroller of the Currency. (2021, September 29). OCC Approves Innovation Bank Charter for Moneycorp. Retrieved from https://www.occ.gov/news-events/news-releases/2021/nr-occ-2021-150a.html [5] Federal Reserve Board. (n.d.). Master Accounts and Participation. Retrieved from https://www.federalreserve.gov/paymentsystems/masteraccounts.htm
- As Ripple works towards getting access to the Federal Reserve's payments infrastructure, it's evident that technology-driven finance companies are leveraging national trust bank charters to gain access to critical American business infrastructure, such as the Fed master account for direct connection to Federal Reserve payment systems.
- In light of the evolving regulatory landscape, fintechs, like Wise and Fidelity Digital Assets, are utilizing national trust bank charters to streamline their operations and scale up rapidly while complying with a single set of federal regulations, benefiting from the operational advantages they offer in technology-intensive business environments.
