Circle Wins Final OCC Approval for a National Trust Bank

Circle received final approval from the Office of the Comptroller of the Currency on July 10 to operate First National Digital Currency Bank, N.A., a national trust bank that will do business as Circle National Trust. The OCC had granted the entity conditional approval in December 2025, on an application filed on June 30, 2025; the final approval is the step that allows it to open. A national trust bank is a federally chartered institution limited to fiduciary and custody work — it does not take deposits or make loans — and it answers to the OCC rather than to a state banking regulator. For the issuer of a dollar stablecoin, the practical effect is that reserve assets and customer holdings can sit inside an entity Circle itself owns and a federal supervisor examines, instead of depending on third-party banks and custodians.

The Charter: Fiduciary Powers Without Deposits or Lending

A trust charter is narrower than a bank charter and that narrowness is the point. The institution acts as a fiduciary — holding and administering assets for others under a legal duty of care — and is barred from the deposit-taking and lending that define a commercial bank, so it carries no federal deposit insurance and none of the credit risk that comes with a loan book. In exchange it gets a national footprint and a single federal examiner, replacing the patchwork of state trust and money-transmitter licences that custody businesses have historically assembled. The OCC's approval covers three lines of activity:

Fiduciary digital-asset custody for Circle and its affiliates.
Potential direct custody for institutional customers, including banks and regulated derivatives organisations.
Future management of the USDC reserve under federal oversight.

The Reserve: Backing Held Inside the Issuer's Own Entity

The third item is the one that changes how the stablecoin itself works. USDC is backed by a reserve of dollar assets, and that reserve has been held through outside banks and asset managers; bringing its management inside a nationally chartered trust puts the assets that back the token under the same federal supervision as the entity issuing it. That removes a layer of counterparty dependence — a partner bank's condition stops being a variable in whether the token can be redeemed — and it consolidates functions that were previously paid for externally, at a time when the economics of issuing a dollar stablecoin have come under competitive pressure. Circle said the trust may also custody assets directly for institutional clients, which would make the charter a revenue line rather than only an internal cost saving.

The Sony Filing: Conditional Approval a Day Earlier

The approval came a day after the OCC granted conditional approval to Connectia Trust, National Association, a New York-based entity capitalised at $40 million and wholly owned by Sony Bank, part of Sony Financial Group, to establish a national trust bank supporting the issuance and management of dollar-denominated stablecoins. The two decisions mark the two ends of the same process. Conditional approval permits an applicant to organise the institution and satisfy the conditions the OCC attaches; only final approval lets it operate, which is why Connectia has no launch date and no guaranteed token issuance, while Circle's entity does not face that constraint. Circle's own path from conditional to final approval took roughly seven months.

What Changes Next: An Established Route and an Unstated Timetable

With one national trust charter fully approved and another conditionally granted inside two days, the OCC route is now a demonstrated path for stablecoin issuers rather than a theoretical one, and applicants can point to a completed file. What was not disclosed is a schedule: neither the announcement nor the OCC decision set a date for moving USDC reserve management into the trust, or for opening custody to outside institutional clients, both of which are permitted rather than required. Connectia still needs its final approval before it can do anything at all. Meanwhile issuers operating across borders face a second set of constraints, with supervisors elsewhere setting their own limits on stablecoin issuance, so a US federal charter settles the domestic supervisory question without settling the others.