The future of Bitcoin’s Fidelity-clearing bank charter and Wyoming SPDI

The OCC charter surge and institutional scale

Coinbase received conditional approval for its national trust bank charter on April 2, 2026. This status puts the exchange in a group of eleven companies that received conditional approvals between December 2025 and March 2026, including Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos. These firms operate under a single national regulator rather than a patchwork of dozens of state agencies. The SEC-CFTC Joint Harmonization Initiative of March 2026 classified 16 tokens as digital commodities, which provided a federal framework for asset classification. This regulatory shift follows an OCC amendment on February 27, 2026, which replaced the term fiduciary activities with operations of a trust company and activities related thereto. The SEC also updated its custody guidance to permit registered investment advisers and funds to use both state and federally chartered trust companies as qualified custodians. This guidance requires written policies for safeguarding assets, segregated client holdings, and annual audits including SOC reports.

Fidelity manages $5.5 trillion in assets under administration across 3,300 wealth management firms and implements a transaction charge of 5% of the purchase value for certain ETFs, which stays capped at a maximum of $100 per client buy order. The firm processes 5.5 million daily trades across 48 capital markets and 21 currencies. Coinbase is the custodian for 9 of 11 spot Bitcoin ETFs and 8 of 9 Ethereum ETFs. Coinbase holds $300 billion in assets under custody. Revenue for custodians like Fidelity comes from transaction charges, expenses from fund companies, and interest revenue from cash sweeps and the lending of liquid holdings. Fidelity also collects fees from ETF sponsors to support shareholder services, analytical tools, and investment research.

State-level frameworks in Wyoming and Nebraska

Wyoming provides an alternative via its special-purpose depository institution charter. Companies using this charter act as banks but cannot lend money or rehypothecate customer assets. Kraken secured this charter in September 2020. All customer deposits must stay in cash, Treasury bills, or other high-quality liquid assets. This model is different from federal trust charters that allow for fiduciary work without traditional banking powers.

Nebraska also created a state banking charter that allows companies to become digital asset depositories. The Nebraska law requires every stablecoin to have backing by a dollar in a federally insured account. Nebraska’s law also allows existing state banks to form digital asset depository departments. Senator Mike Flood says that using the word "bank" conveys weight to consumers. Illinois has proposed similar legislation that would create special purpose trust companies for crypto startups. The Illinois bill passed the House and awaits a Senate vote.

The battle over stablecoin yields and bank deposits

The ICBA and ABA oppose the expansion of crypto firms into the federal banking system. ICBA President Rebeca Romero Rainey says that crypto firms pursue master accounts and national trust charters without meeting the same regulatory requirements as banks. These organizations fear that stablecoins offering 4% to 5% yields will pull deposits away from community banks. Such a drain would reduce lending for consumers, small businesses, and farmers. The ABA urged bank CEOs to contact senators ahead of the Senate Banking Committee’s vote on the CLARITY Act. Patrick Witt, an official for the President’s Council of Advisors for Digital Assets, said the White House was beneath the bank trade CEOs when they refused to attend meetings to resolve the stablecoin rewards issue.

The OCC released its final debanking report on October 14, 2026. This review covered the period from 2020 to September 2025 and examined the nine largest national banks. The OCC found that banks had broad reputation risk policies without clear, objective, risk-based criteria. These policies disadvantaged customers based on their views or their lawful business activities. While banks reported removing restrictions on digital assets, the OCC warned that some business lines still decline to serve digital asset issuers based on claimed operational limits. The FSB released a report on October 12, 2026, expressing concern over the $300 billion stablecoin market. The report notes that holders of stablecoins can trade pseudonymously across borders 24 hours a day. This creates risks when reserves and legal protections stay tied to particular jurisdictions.

The distinction between distribution and balance sheets

The regulatory environment distinguishes between distribution licenses and balance sheets. A national trust charter is a distribution license, providing federal oversight for custody and minting activities. A national bank charter is a balance sheet, allowing for lending and taking deposits. OpenReserve and Revolut received preliminary approval for full-service national bank charters. These charters allow firms to intermediate finance rather than just providing custody. OpenReserve requires $210 million in capital and a 12% Tier 1 leverage ratio for its first three years.

The OCC attaches specific capital and liquidity requirements to conditional approvals. Bastion must maintain $6 million in tier 1 capital, while Agora and Catena must maintain $10 million. These institutions must also hold liquid assets sufficient to cover 180 days of operating expenses. The OCC recently rejected two applications, including the British fintech Wise’s national trust charter bid in July. You should monitor the June 30, 2027, deadline for firms holding under $100 million with Fidelity. Will the OCC eventually force crypto firms to adopt traditional banking capital requirements before granting final approval?