Written by: Liam 'Akiba' Wright
Compiled by Saoirse, Foresight News
On September 18, the U.S. Office of the Comptroller of the Currency (OCC) advanced federal trust bank charter applications for three institutions focused on stablecoin businesses, applying a unified regulatory framework to the reviews of Agora, Catena, and Bastion.
This series of approvals confirms that the OCC is establishing a replicable approval pathway for these narrow, non-deposit-insured trust banks. However, this pathway still carries implementation and legal risks: Agora and Catena must obtain final approval before opening; Bastion must complete its charter conversion; the regulatory framework for stablecoins has not yet been finalized; and state regulators continue to challenge the scope of the OCC’s supervisory authority.
This also determines the competitive significance of this matter. Federal trust chartering can reduce regulatory fragmentation by consolidating related activities under a single regulatory authority. However, the sequential issuance of conditional approvals means that the charter itself is unlikely to serve as a lasting moat. Final approval, distribution channels, capital requirements, reserve partnerships, and operational performance represent far more stringent challenges.
What did the OCC actually approve?
The rulings on Agora and Catena grant preliminary conditional approval to the newly established national trust banks. Both applicants are still in the organizational phase and must complete all pre-opening preparations before the OCC issues final approval and authorizes them to begin operations.
Bastion’s approval pathway differs. Bastion Platforms Trust Company previously operated under a New York State trust charter. The OCC conditionally approved its transition to Bastion Platforms National Trust Company, subject to various prerequisites and the submission of a confirmation of completion, after which it may operate under a national trust charter.
This distinction separates regulatory approval progress from actual operational authorization. Agora and Catena are establishing entirely new federal institutions; Bastion is transforming an existing state trust company. The approval documents do not specify a confirmed opening date for any of the three institutions.
Agora and Catena must submit a letter to the OCC licensing review team at least 60 days before their planned opening. If capital raising is not completed within 12 months, or if operations do not commence within 18 months, the approval will expire. Bastion’s approval will automatically terminate if the transition is not completed within six months, unless the OCC grants an extension under exceptional circumstances.
All three approval decisions are based on a unified trust company regulatory framework, but do not grant identical business permissions. Each institution’s activities must be limited to the permitted trust company business and associated services, and must not fall within the definition of “bank” under the Bank Holding Company Act.
The institution approved for establishment is not a conventional deposit-insured commercial bank. Bastion’s approval documents explicitly state that the institution does not accept deposits and is not insured by the Federal Deposit Insurance Corporation (FDIC). Agora’s letter confirms that the proposed bank is not a deposit-insured institution. Catena’s approval documents classify the institution as a national bank without deposit insurance and explicitly state that payment stablecoins are not deposits and may not be represented as FDIC-insured.
Capital requirements follow a unified framework while also establishing individual standards for different applicants. Agora and Catena must each maintain at least $10 million in Tier 1 capital; eligible liquid assets must equal the higher of 50% of Tier 1 capital or $5 million. Bastion’s minimum Tier 1 capital requirement is $6 million; eligible liquid assets must equal the higher of 50% of Tier 1 capital or $3 million. All institutions must reassess their capital and liquidity levels quarterly and increase capital and liquid assets if their risk profile changes.
Another common requirement: All three institutions must hold sufficient eligible liquid assets to cover 180 days of fixed and variable operating expenses under a crisis liquidation scenario. These assets must not be double-counted with those used to meet liquidity requirements under capital adequacy. This requirement applies during the first three years of operation following receipt of a federal license.
On September 18, 2026, the OCC granted conditional trust charters of different types to Agora, Catena, and Bastion. Each institution has distinct capital requirements and business focuses; all are national trust companies without deposit insurance and are required to maintain separate funds sufficient to cover 180 days of liquidation expenses. Opening or transition of qualifications has not yet been completed.
OCC also requires that any significant changes to business plans be communicated in advance to the regulatory authority and receive written non-objection. Compliance, auditing, information security, and corporate governance are all essential requirements for opening or completing a transition.
Why is the licensing approval pathway replicable?
The approvals on September 18 are just one part of a broader trend. The OCC’s approval records include decisions related to digital asset trust banks for multiple institutions, such as Bridge, Foris DAX, Coinbase, Laser Digital, Wise, and World Liberty. The agency’s digital asset applications page shows that numerous other applications are still pending review.
In August, Comptroller Jonathan Gould stated that of the 40 new license applications received over the past approximately 18 months, 23 involved digital assets. This number does not guarantee that applicants will ultimately be approved, but it indicates that the three companies granted conditional licenses on September 18 are not isolated pilot cases—they are part of this same group of applicants.
The OCC’s new regulations for trust banks, effective April 1, 2026, further clarify that national trust banks may engage in compliant non-trust business in addition to trust services. The OCC will continue to evaluate the statutory authority for each proposed activity on a case-by-case basis, meaning that each applicant’s application will be individually assessed, even if a clear approval pathway exists.
The draft implementing regulations for the GENIUS Act aim to establish uniform reserve, capital, and liquidity standards for federal stablecoin issuers. As of September 22, the regulations remain a draft and outline a potential federal standardized regulatory framework, but are not yet finalized operational rules.
Legal foundations remain contested. The Conference of State Bank Supervisors has questioned the scope of the OCC’s trust charter and its preemption authority; state regulators have indicated that, if such charters are deemed to exceed the bounds of the National Bank Act, litigation could be initiated in the future. Although no formal lawsuit has yet been filed, this situation illustrates that a viable regulatory approval process does not equate to settled law.
Therefore, the core perspective of this article is comparative. The three approval decisions remain consistent in key regulatory boundaries, capital rules, clearing liquidity, prior regulatory notification, and pre-opening controls. Additional approval files and pending applications indicate that the OCC is applying this regulatory framework to more institutions. The threshold for applying for a federal trust charter remains high, and regulatory requirements are stringent, but this qualification is increasingly resembling an infrastructure available to qualified applicants.
Under a unified regulatory framework, each entity can still develop differentiated businesses.
Agora’s solution: Provides USD-backed stablecoin issuance and reserve maintenance for institutional and corporate custodial clients, along with digital asset custody, custodial-related payment and settlement services, and fiduciary investment advisory services. According to the OCC filing, Agora plans to transfer the AUSD stablecoin issuer from Agora Bermuda only after the new bank is established. This migration will transfer the underlying assets and accounts, with the federal trust bank assuming responsibility for the reserve assets and corresponding liabilities.
However, this transition remains in the planning stage. As of September 22, Agora’s AUSD product page still lists Agora Bermuda as the issuer. The product page outlines the reserve management, custody, and partner ecosystem that determine Agora’s distribution channels. Agora’s approved announcement also states that final approval is still pending.
The bank planned by Catena targets a different customer segment. The approved business plan includes fiduciary and non-fiduciary custody, fiduciary investment management, trust services, and non-fiduciary asset conversion, clearing, and execution services配套 with custodied assets. Catena has publicly announced that its entire business framework is built around AI agents and enterprise clients deploying such agents. Focusing on AI is Catena’s own business strategy, not a regulatory classification provided by the OCC.
Bastion’s business model is centered on enterprise infrastructure. The approved scope of transformed operations includes custodial wallet services, custodied asset exchange for clients, and white-label stablecoin issuance, while also providing technology and operational services to other compliant issuing entities. Bastion states that enterprise customers can utilize custodial, payment, and issuance tools, with third-party institutions still serving as the legal registrants for issuance. Bastion announced that this federal licensing transition will consolidate the various business capabilities currently supported by its New York State trust charter, other licenses, and partnerships.
These business differentiators highlight the sources of future competitive advantage. A license provides nationwide regulatory coverage and consolidates compliant operations under a single regulatory authority. However, a license alone cannot attract customers, liquidity, reserve partners, or enterprise system integration, nor can it guarantee the successful launch of a project.
Previous articles have regarded the federal trust charter as a scarce strategic asset. When reporting on Agora’s pending application and the rise of narrow-purpose crypto banks, they emphasized the charter’s nationwide operational reach while also highlighting its limitations. Another analysis examining the competitive impact of the GENIUS Act concluded that being first to secure federal access would benefit well-capitalized stablecoin issuers.
The approval results on September 18 weakened the argument of "license scarcity." On the same day, three approvals were issued with highly similar regulatory boundaries, regulatory frameworks, and pathways for commencement or transition, differing only in capital requirements, customer targeting, and business models.
The importance of implementation has been elevated. Agora and Catena must convert their preliminary approvals into operating licenses; Bastion must complete its transformation. All three institutions must continuously maintain capital and clearing liquidity while convincing clients of the validity of their custody, issuance, settlement, and risk management service offerings.
The federal trust charter still holds value in this market, but it is increasingly becoming an entry barrier; sustainable competitive advantages must be built through channel distribution, liquidity management, and operational execution.