Circle Wins Final OCC Approval for a National Trust Bank

The Office of the Comptroller of the Currency gave Circle its final approval 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 file behind the decision stretches back a year. Circle applied on June 30, 2025 and had conditional approval in hand by December 2025, so the final sign-off is the step that lets the institution open. A national trust bank is a federally chartered institution limited to fiduciary and custody work; it takes no deposits and makes no loans, and it answers to the OCC instead of 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, not at third-party banks and custodians.

A charter built to be narrow

The narrowness is the point. A trust charter grants fiduciary powers, meaning the institution holds and administers assets for others under a legal duty of care, and it bars the deposit-taking and lending that define a commercial bank. So there is no federal deposit insurance, and no loan book carrying credit risk. What the charter buys in exchange is a national footprint and a single federal examiner, in place of the patchwork of state trust and money-transmitter licences that custody businesses have historically stitched together. 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 comes in-house

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 so far been held through outside banks and asset managers. Bringing its management inside a nationally chartered trust puts the assets behind the token under the same federal supervision as the entity that issues it. A partner bank's condition stops being a variable in whether the token can be redeemed. It also pulls in-house functions Circle previously paid for externally, at a moment 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.

Sony had its answer a day earlier

Circle's approval landed 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. Read together, the two decisions show both ends of one process. Conditional approval lets an applicant organise the institution and satisfy the conditions the OCC attaches; only final approval lets it operate. That gap is the reason Connectia has no launch date and no guaranteed token issuance, while Circle's entity faces no such constraint. Circle's own run from conditional to final took roughly seven months.

Permitted, not scheduled

With one national trust charter fully approved and a second granted conditionally inside two days, the OCC route is now a demonstrated path for stablecoin issuers, and the next applicant can point to a completed file. What nobody has published is a timetable. Neither the announcement nor the OCC decision sets a date for moving USDC reserve management into the trust, or for opening custody to outside institutional clients; both are permitted, not required. Connectia, for its part, can do nothing until its final approval comes through. Issuers operating across borders still 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 and leaves the others where they were.