Circle National Trust launches federal charter without retail banking powers

Circle received a federal trust charter from the Office of the Comptroller of the Currency on Friday, establishing Circle National Trust as the fourth member of a new class of crypto-native financial institutions. The charter authorizes custody, fiduciary administration, stablecoin reserve management, and settlement activities. It does not grant deposit-taking powers, FDIC insurance, or the ability to issue mortgages or consumer loans. The OCC's conditional trust framework, introduced in 2020, was designed for firms that hold digital assets on behalf of clients without engaging in traditional banking. Anchorage Digital Bank, Paxos Trust Company, and Protego Trust Bank received charters under the same structure between 2021 and 2022. Each operates as a non-depository trust company subject to OCC supervision, capital requirements, and anti-money-laundering obligations. CoinGecko data shows Circle's USDC reserves, which totaled $34.8 billion at the last attestation, continue to be held primarily at BNY Mellon and in short-term Treasury repurchase agreements. The charter does not change the reserve composition or the monthly attestation schedule published by Grant Thornton. Circle Chief Executive Jeremy Allaire has previously stated that a federal charter would strengthen regulatory clarity for USDC without altering its operational model. The OCC has not signaled whether a fifth charter is pending. Industry participants note that the conditional trust structure requires applicants to demonstrate a viable business model, adequate capital, and a compliance program tailored to digital-asset risks. A 2023 Government Accountability Office report found that the OCC had not yet established public metrics for evaluating charter applications, leaving timing uncertain. Market observers are watching for two developments: whether the Federal Reserve will grant master-account access to any trust-chartered firm, and whether state regulators will recognize the OCC charter as satisfying money-transmitter licensing requirements. Neither outcome is guaranteed. The Fed has historically reserved master accounts for depository institutions, and state money-transmitter laws vary widely in their treatment of federal trust companies. Circle's charter takes effect immediately. The company has not announced changes to USDC issuance, redemption, or reserve-management procedures.