Coinbase Trust Bank Opens: What Changes, and for Whom

Coinbase announced final OCC approval on November 9, and the regulator’s application register records Coinbase National Trust Company as effective from November 6.

Rick Schonberg, Coinbase’s head of prime trading and custody, said in the company’s release that the approval “allows us to expand our custody capabilities within a consistent federal regulatory framework,” American Banker reported. Whether that expansion reaches a given customer depends on which Coinbase company they actually deal with.

Three Coinbase companies, three kinds of customer

The group now runs three regulated entities with different supervisors and different clients. The one a customer contracts with decides which rulebook covers their assets and which documents would record any change.

For retail users, the answer is already in the paperwork. Coinbase’s U.S. individual user agreement, updated October 21, is a contract with Coinbase, Inc. The OCC’s approval covers the transfer of CCTC’s institutional custody business, and neither Coinbase’s announcement nor the regulator’s filings place retail accounts inside that plan.

Prime clients are the ones with a transition ahead of them. Coinbase’s Prime Custody documentation names CCTC as the custodian, and that is the business the OCC decision describes moving into the federal trust.

The largest single category inside that business is ETF custody. The iShares Bitcoin Trust prospectus names CCTC as its bitcoin custodian, with Anchorage Digital Bank as an alternative and Bank of New York Mellon holding the cash. A change of custodian for a fund of that kind shows up in its SEC filings, so the prospectus is the document to read, as Coindoo explained in its look at how ETF custody arrangements shape investor risk.

What a federal charter adds

Coinbase has operated under state licences for nearly a decade, and it describes the federal charter as a move from state to national oversight. According to American Banker, the company sees two advantages: federal preemption of some state financial laws for OCC-regulated entities, and a single set of rules under the agency’s recently finalised framework for trust banks.

The charter also carries hard financial conditions. The OCC’s April 2 decision requires at least $60 million in tier 1 capital, the highest-quality capital made up mainly of shareholder equity, throughout the first three years. It also requires eligible liquid assets equal to the greater of half that capital or $30 million, plus a separate liquidity buffer covering 180 days of operating expenses. Those are minimums the trust must hold, not a report of what it holds today.

Coinbase joins a growing group. Anchorage Digital Bank has held an OCC charter since January 2021, Ripple received final approval in late October, and the OCC conditionally approved five crypto firms in December 2025 before Coinbase’s own conditional approval in April, which Coindoo covered when the charter was first granted.

The banking industry disputes the whole model. Trade groups have sued the OCC over its interpretation of the trust charter, arguing that it lets crypto firms operate like banks without bank-level requirements while holding customer assets that carry no deposit insurance. American Banker reports that the litigation could run for years, and that a court ruling against the OCC would still leave open what happens to institutions already chartered under the contested reading. Coinbase’s charter is in force today; its long-term legal footing is being tested in parallel.

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How the three-year transfer works

The April decision describes a planned migration of CCTC’s custody business into the new trust during the trust’s first three years. That window is an outer limit, not a schedule. Some clients may move early, others later, and neither Coinbase nor the OCC has published figures on how much business has transferred so far.

A Prime client learns the date of their own transition from their custody agreement, any assignment or amendment notice, and the effective date printed on it. The same documents name the entity responsible for the account from that date. Whether the move requires fresh signatures or any onchain transfer of coins is a question the public filings leave open, and Coinbase has not said.

Wallets, insurance and cash stay as they were

Federal supervision changes who examines the custodian, not how the coins are stored. Coinbase’s charter application describes two models: Prime Vault, with customer-specific blockchain addresses, and Prime Custody, where assets sit in omnibus wallets that are legally segregated but operationally pooled. Customer entitlements are tracked in the custodian’s records rather than through separate addresses.

That arrangement fits the federal rule. 12 CFR 9.13 requires fiduciary assets to stay separate from the bank’s own, and between client accounts it permits either physical separation or identification of the investments as belonging to a particular account. A dedicated wallet remains a product choice, not a regulatory requirement.

Insurance does not change either. The FDIC excludes crypto assets from deposit insurance, including when a bank offers the product. The capital and liquidity minimums above protect the institution’s solvency; they are not a reimbursement promise to any individual client.

Client dollars follow a different path. The OCC decision describes fiat custody through accounts held at third-party banks for customers’ benefit. Any deposit insurance there depends on the partner bank, the account structure and the record-keeping conditions for pass-through coverage, none of which the trust’s own charter supplies.

Custody at the trust, services from affiliates