Federal Trust Charters Advance for Three Stablecoin Firms, but Operational Hurdles Remain

The Office of the Comptroller of the Currency (OCC) moved three stablecoin‑focused firms closer to federal trust‑bank status on September 18. While the decisions illustrate a repeatable regulatory pathway for narrow, uninsured trust banks, each firm still faces significant steps before it can begin operations.

What the OCC approved

Agora and Catena received preliminary conditional approval to form new national trust banks. Both must complete pre‑opening work, raise the required capital, and submit a notice at least 60 days before any scheduled launch. Their approvals expire if they fail to raise capital within 12 months or open within 18 months.

Bastion Platforms Trust Company, already operating under a New York trust charter, was conditionally approved to convert to a national trust company. The conversion must be completed within six months, or the approval terminates unless the OCC grants an extension.

Capital and liquidity requirements

• Agora: minimum $10 million tier‑1 capital; liquid assets equal to the greater of 50 % of tier‑1 capital or $5 million.
• Catena: same $10 million tier‑1 capital and liquid‑asset floor as Agora.
• Bastion: minimum $6 million tier‑1 capital; liquid assets equal to the greater of 50 % of tier‑1 capital or $3 million.

All three must hold eligible liquid assets sufficient to cover 180 days of fixed and variable operating expenses for a distressed wind‑down, separate from the liquidity supporting the capital floor. These requirements apply during the first three years of operation.

Operational limits

The OCC requires each institution to remain outside the Bank Holding Company Act definition of a bank and to limit activities to trust‑company services. None will be FDIC‑insured deposit takers. Agora and Catena will treat payment stablecoins as non‑deposits, while Bastion explicitly will not accept deposits.

Broader regulatory context

The September decisions are part of a growing cohort of digital‑asset trust‑bank applications. The OCC’s 2026 trust‑bank rule, effective April 1, permits certain non‑fiduciary activities alongside fiduciary services, but each application is still assessed case‑by‑case. Proposed GENIUS Act rules, still pending as of late September, aim to standardize reserve, capital and liquidity expectations for federal stablecoin issuers.

State banking supervisors, organized through the Conference of State Bank Supervisors, have challenged the breadth of the OCC’s trust‑charter approach, indicating potential future litigation over the statutory authority of such charters.

Business models under review

Agora plans to issue a dollar‑backed stablecoin (AUSD), manage reserves, provide digital‑asset custody, payments and advisory services for institutional clients. Catena’s model focuses on fiduciary and non‑fiduciary custody, investment management, and AI‑driven services for businesses. Bastion’s conversion targets enterprise infrastructure, offering custodial wallets, white‑label stablecoin issuance and technology services for other issuers.

While a federal trust charter can reduce regulatory fragmentation and provide a single supervisory framework, the real competitive advantage will depend on each firm’s ability to secure customers, liquidity partners and operational execution.