Modern Treasury Seeks OCC Charter for National Stablecoin Custody and Settlement Bank
Oct. 5, 2026 • Article • Digital Assets
Modern Treasury applied to the Office of the Comptroller of the Currency on October 5, 2026, to establish a limited-purpose national trust bank focused on stablecoin custody and settlement. The proposed institution would connect stablecoin and fiat transactions with the company’s existing payment infrastructure under direct federal supervision. Its software and payment services would remain separate.
The bank would safeguard client assets and facilitate settlement, but would not make commercial loans, accept retail demand deposits or issue a stablecoin. The application follows Modern Treasury’s 2025 acquisition of Beam, which expanded its stablecoin payment capabilities. A national trust charter could provide a single federal framework for authorized custody and fiduciary services.
The filing is in the OCC’s initial review and public comment stage. The bank cannot open without final authorization and satisfaction of pre-opening requirements. Modern Treasury’s bid comes amid growing scrutiny of digital-asset trust charters, with traditional banking groups raising concerns about FDIC coverage and banking safeguards.
Modern Treasury submitted a formal application to the Office of the Comptroller of the Currency on October 5, 2026, seeking to establish a limited-purpose national trust bank focused on stablecoin custody and settlement.
The proposed Modern Treasury National Trust Bank would connect stablecoin and fiat movements with the company’s existing payment infrastructure. If approved, the institution would operate under direct OCC supervision and provide Modern Treasury with a unified federal structure for custody and settlement services.
The application is still at an early stage. It is undergoing the OCC’s initial regulatory review and public comment process before the agency considers whether to grant preliminary conditional approval. The trust bank cannot begin operating unless it satisfies all pre-opening requirements and receives final charter authorization under 12 U.S.C. 27(a).
A Limited-Purpose Trust Model
Modern Treasury’s proposed institution would have a narrower mandate than a conventional commercial bank. It would not engage in commercial lending, accept retail demand deposits or issue its own stablecoin.
Instead, its role would center on custody and settlement. Custody generally involves safeguarding assets on behalf of clients, while settlement covers the completion of transactions and movement of funds between parties. Modern Treasury aims to combine those functions across stablecoin and traditional fiat payment flows.
That structure would build on the company’s existing payment rails while preserving a separation between regulated banking activities and its current technology services. Modern Treasury said its core software business and payment service provider operations would remain legally and operationally distinct from the proposed bank.
The distinction is significant because a national trust bank charter does not provide the same scope of activities as a full-service bank charter. Although it creates a federally supervised framework for fiduciary and custody services, it also limits the institution’s ability to conduct conventional banking activities.
Extending Modern Treasury’s Stablecoin Strategy
The charter application follows Modern Treasury’s expansion into stablecoin payments through its acquisition of Beam in October 2025. That deal integrated stablecoin payment capabilities into the company’s platform.
Establishing a national trust bank would extend that strategy by bringing custody and settlement into a federally regulated entity. The planned model is designed to support both stablecoin and fiat movements rather than operate as a stablecoin issuer.
A national trust charter can also provide nationwide federal fiduciary preemption, allowing an institution to offer covered services through a single federal structure instead of obtaining separate money transmitter licenses in all 50 states. However, the charter would bar the institution from accepting retail demand deposits.
For Modern Treasury, the proposed structure would place the regulated trust functions within the bank while leaving its software and payment services outside it. Operations cannot start unless the OCC completes its review, grants the necessary approvals and confirms that the institution has met its pre-opening conditions.
OCC Charters Face Industry Scrutiny
Modern Treasury’s filing comes as the OCC considers and approves more national trust bank applications from fintech and digital-asset companies. The regulator conditionally approved at least a dozen national trust charters for fintech and crypto businesses during 2026. Agora, Catena and Bastion Platforms received conditional approvals in September 2026.
The trend has drawn opposition from traditional banking organizations and community banks. Those groups have pursued regulatory and legal challenges, arguing that national trust charters for crypto-focused businesses can bypass Federal Deposit Insurance Corporation coverage and key safeguards under the Bank Holding Company Act.
That dispute reflects the unusual position of limited-purpose trust banks. They can obtain federal supervision and operate nationally in their authorized areas without becoming conventional deposit-taking banks. Supporters of the structure view it as a unified regulatory route for custody and fiduciary services, while critics question whether existing rules provide sufficient oversight for institutions dealing with digital assets.
Approval Process Remains Ahead
Modern Treasury’s application does not constitute authorization to launch the bank. The OCC must first complete its initial review and public comment process. It may then consider preliminary conditional approval, which would typically require the applicant to satisfy specified organizational and operational conditions before opening.
Final authorization remains contingent on compliance with all pre-opening requirements. Until that process is complete, Modern Treasury National Trust Bank remains a proposed institution rather than an operating bank.
The outcome will determine whether Modern Treasury can place stablecoin custody and settlement within a directly supervised national trust entity while maintaining its existing software and payment operations as separate services.
Mastercard and Visa are extending stablecoin technology into the systems that settle card payments between financial institutions, while leaving the consumer checkout experience largely unchanged. Mastercard completed its acquisition of stablecoin infrastructure provider BVNK in August 2026 and has expanded its network’s settlement options to include regulated stablecoins. Visa, meanwhile, is working with Stripe-owned Bridge and Lead Bank on on-chain settlement for card programs. The shift became more concrete in September, when SoFi Bank moved its credit and debit card issuing portfolio to live settlement using its bank-issued SoFiUSD. That portfolio represents more than $25 billion in annualized card volume, a measure distinct from the value settled in stablecoins. Visa separately reported an annualized stablecoin settlement run rate exceeding $25 billion in October. The networks’ initiatives target the back-end movement and reconciliation of funds, including periods when traditional bank settlement rails are unavailable; they do not require merchants to accept cryptocurrency.
The European Central Bank has launched Pontes, a bridge connecting tokenised-asset platforms to the Eurosystem’s TARGET Services for wholesale settlement in central bank money. The arrangement enables atomic delivery-versus-payment settlement, in which an asset and its payment move together. It does not yet make wholesale settlement available around the clock: Pontes depends on T2 operating hours and requires tokenised central bank money balances to be defunded at the end of the day. ECB Executive Board member Piero Cipollone says the Eurosystem plans to extend Pontes operating hours substantially by mid-2027 and reach 24/7/365 availability in 2028. Separately, the Bank for International Settlements’ Project Agorá has tested cross-border payments using a shared programmable ledger that brings tokenised commercial bank deposits and central bank reserves into a single settlement process. Both initiatives address delays and liquidity demands in wholesale payments, but neither makes continuous, cross-border settlement available today.
Project Agorá’s real-value testing settled 30 live, multi-currency transactions worth approximately CHF 800,000, with atomic settlement averaging about 80 seconds. The tests involved 28 commercial institutions and five central banks. The result shows how tokenised commercial bank deposits and central bank reserves could support faster cross-border settlement, though it does not establish that settlement latency has been eliminated. The project’s prototype found that tokenisation did not change the legal character or regulatory obligations of deposits and reserves. Its design also let participating institutions conduct compliance checks concurrently. Seven more commercial banks joined in September 2026, taking private-sector participation to nearly 50 institutions. At Sibos in October, banking executives described the testing pipeline as a step towards production trials alongside the European Central Bank’s Pontes platform. The Federal Reserve Bank of New York did not participate in the live test transactions, an important qualification for the US dollar tests.
Ripple’s final federal trust bank charter, a Moody’s investment-grade rating for RLUSD and a planned expansion of the stablecoin’s availability on Coinbase have strengthened its position as a regulated digital dollar. Coinbase said Global Exchange access, including eligibility to use RLUSD as trading collateral, will follow its initial retail and prime rollout. Moody’s assigned RLUSD an A2 long-term deposit rating and a P-1 short-term rating, the first investment-grade rating it has given a stablecoin. The distinctions behind those developments matter. Ripple National Trust Bank manages RLUSD’s reserve collateral, but the legal issuer remains Standard Custody & Trust Company, a New York-regulated Ripple subsidiary. The national trust bank is uninsured and cannot take commercial retail deposits or extend credit. Moody’s also noted that holders do not currently own the underlying reserves directly and that statutory bankruptcy protections depend on implementation of the GENIUS Act, whose rules take effect in January 2027.
Ramp partnered with Stripe and Bridge in July 2026 to deploy stablecoin rails for business bill payments and yield-bearing stablecoin accounts funded through standard fiat bank accounts. The arrangement shows how stablecoins can be incorporated into familiar payment workflows without requiring businesses to fund every transaction with digital assets. The economics depend on more than the cost of moving a token on-chain. Stripe charges merchants 1.5% for stablecoin checkout transactions, versus its standard card-processing fee of 2.9% plus $0.30; neither figure establishes the price of Ramp’s bill-payment service. Businesses receiving fiat may also face foreign-exchange and off-ramp costs, typically 0.3% to 2.0% when converting into local banking systems. Domestic clearing networks and compliance checks remain part of end-to-end delivery. Bridge’s issuance and transfer tools, alongside its conditional U.S. trust-bank approval, illustrate the infrastructure behind those payments—but not the elimination of every payment cost.
StraitsX has opened onboarding for digital payment token providers across more than 100 markets through an expanded card-issuing architecture developed with Visa. Integration documentation published on 26 October 2026 describes a multi-BIN model that combines issuing sponsorship, transaction authorization, compliance screening and fiat clearing. The approach lets participating providers build stablecoin-backed card products while merchants continue to receive conventional fiat payments through Visa’s network. StraitsX says its card gross transaction value rose 40-fold year on year from Q4 2024 to Q4 2025, while cards issued across Asia increased 83-fold. On-chain issuer telemetry recorded monthly card transaction volume of $310 million to $438 million through October 2026. The company’s stated $6 billion annualized card transaction figure is distinct from its cumulative $70 billion in processed stablecoin volume. StraitsX and Visa have also scheduled demonstrations of agentic payments for November 2026.