ICBA Opposes OCC Approval of Coinbase’s National Trust Bank Charter Application

Washington, D.C. (April 2, 2026) - The Independent Community Bankers of America (ICBA) today expressed opposition to the Office of the Comptroller of the Currency's conditional approval of Coinbase's application for a national trust bank charter for its subsidiary, Coinbase National Trust Co.

"Today's conditional approval of Coinbase's trust charter application is a grave mistake that will only serve to put U.S. consumers at risk," ICBA President and CEO Rebeca Romero Rainey said. "As ICBA detailed in our letter to the OCC opposing Coinbase's effort to procure a national trust charter, its application fails to meet requirements of the National Bank Act and the OCC's own regulations and standards. We also continue to have significant concerns with the OCC's chartering rule for national trust banks, which is inconsistent with its statutory authority laid out in legislative history, judicial interpretations, and the agency's own internal precedent."

In its letter to the OCC on Coinbase's application, ICBA noted significant deficiencies with the application, including flawed risk and control functions, profitability challenges, and resolution risks.

More broadly, ICBA has repeatedly said in letters to the OCC that the agency lacks statutory authority to expand non-fiduciary trust powers and that the sudden influx of applications demonstrates nonbank entities are seeking the benefits of a U.S. bank charter without satisfying the full scope of U.S. bank regulations - threatening consumers and the financial system.

In a recent comment letter on the agency's final rule on national trust bank chartering, ICBA said the OCC's plan to charter uninsured national trust banks that engage in non-fiduciary cryptocurrency-related activities without being subject to the Bank Holding Company Act and other prudential requirements that apply to FDIC-insured institutions poses critical public policy concerns for consumers and the stability of the financial services sector. In the letter, ICBA reiterated its call for the OCC to withdraw the rule or reissue an amended proposal consistent with its own statutory authority.

ICBA looks forward to continued engagement with policymakers on these issues to ensure strong, clear, and consistent oversight of the financial services sector.

About ICBA

The Independent Community Bankers of America® has one mission: to create and promote an environment where community banks flourish. We power the potential of the nation's community banks through effective advocacy, education, and innovation.

As local and trusted sources of credit, America's community banks leverage their relationship-based business model and innovative offerings to channel deposits into the neighborhoods they serve, creating jobs, fostering economic prosperity, and fueling their customers' financial goals and dreams. For more information, visit ICBA's website at icba.org.