Modern Treasury Seeks OCC Charter for National Stablecoin Custody and Settlement Bank

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.