OCC Regulatory Amendment Takes Effect: National Trust Banks Can Hold Crypto in Non-Fiduciary Custody
The OCC removed the last textual ambiguity about what crypto trust banks can do.
What Changed
An OCC amendment effective April 1, 2026, replaces 'fiduciary activities' with 'operations of a trust company and activities related thereto' in 12 CFR 5.20. This eliminates any regulatory text that could have been read as restricting national trust banks to fiduciary custody only. Non-fiduciary custody accounts — essential for crypto custodians — are now unambiguously authorized.
Who It Affects
The 11+ crypto firms that have filed for OCC national trust bank charters, traditional custody banks evaluating digital asset offerings, and any firm whose crypto custody model relies on federal regulatory authorization.
What to Do
If you are pursuing an OCC charter, update your application to reflect the amended regulatory text. If you are evaluating whether a charter fits your business, the scope of permissible activities is now clearer.
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