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The Office of the Comptroller of the Currency (OCC) granted Coinbase conditional approval for a national trust bank charter on April 2. The entity — Coinbase National Trust Company, a de novo non-insured national trust company to be headquartered in New York — will operate as a federally regulated digital asset custodian once it meets the OCC's preopening conditions and receives final approval.
Paul Grewal, Coinbase's chief legal officer, confirmed the development publicly: the company still needs final approval, and its business will not operate under an OCC charter until that approval is granted. The conditional approval is the beginning of a regulatory process, not the end of one. But it is significant precisely because of when it arrived and what else is happening simultaneously.
What the OCC Charter Does
A national trust bank charter gives Coinbase a single federal regulator — the OCC — in place of the patchwork of state money transmitter licences it currently holds. It allows the company to offer custody, safekeeping, and related digital asset services in a fiduciary capacity as a qualified custodian under SEC regulations. It does not permit deposit-taking or lending. It does not resolve the stablecoin yield question. And it does not require the CLARITY Act to pass.
That last point is the one that matters most for understanding where Coinbase sits in the broader legislative picture.
The CLARITY Act Context
On January 14, Coinbase CEO Brian Armstrong stated publicly that the company could not support the Digital Asset Market Clarity Act in its current form, citing the stablecoin yield provisions that would ban passive yield on stablecoin balances. Stablecoin-related revenue represented approximately 20% of Coinbase's total revenue in the third quarter of 2025 — a commercial reality that Coinbase, like other stablecoin platforms, has been open about throughout the negotiations.
Senators Thom Tillis and Angela Alsobrooks reached an agreement in principle on a revised yield framework on March 20. Crypto industry leaders reviewed the new text in a closed-door Capitol Hill session on March 23. Coinbase communicated concerns to Senate staff about the revised language. Armstrong has made no public statement about the March 23 text.
As FinTech Weekly reported in March, the CLARITY Act's stablecoin yield text as it currently stands bans passive yield directly or indirectly — the position banks have sought since negotiations began. Coinbase raised significant concerns after reviewing the draft.
The revised text that Tillis's office described as following further conversations with industry stakeholders, including banks, has not yet been published. The Senate Banking Committee markup is targeted for the second half of April, after Easter recess ends on April 13.
Two Parallel Tracks
The OCC charter and the CLARITY Act stablecoin yield dispute are separate tracks. Conditional approval for a national trust bank charter gives Coinbase federally regulated custody infrastructure. It does not resolve the stablecoin yield question. Those are different regulatory questions governed by different statutory frameworks — and the industry is actively pursuing both simultaneously.
What the OCC approval does do is reinforce the pattern FinTech Weekly identified in March when documenting the eleven-company charter wave: the industry is building federal banking infrastructure regardless of the CLARITY Act's progress. Circle, Ripple, BitGo, Paxos, Fidelity Digital Assets, Bridge, Crypto.com, Protego, Morgan Stanley, Payoneer, and Zerohash all filed or received conditional approvals in an eighty-three day window ending March 5.
Coinbase's conditional approval today extends that wave.
The charter gives Coinbase what the OCC can give — a federal regulatory home for its custody business. The CLARITY Act fight is about something the OCC cannot give: statutory clarity on the treatment of stablecoin yield, codified into law and resistant to reversal by a future administration. Those are different things. Coinbase is pursuing both simultaneously.
What Comes Next
The conditional approval requires Coinbase to meet a series of preopening requirements — compliance systems, risk management frameworks, staffing, and a preopening OCC examination — before the charter becomes final. That process takes months under standard OCC procedure.
On the CLARITY Act side, the revised stablecoin yield text has not yet been published. When it drops, it will be the document that determines whether the outstanding industry concerns can be resolved before Chairman Tim Scott puts a markup on the calendar. Armstrong has not spoken publicly on the CLARITY Act since February, when he described White House conversations as constructive and signalled Coinbase was working toward a compromise.
The OCC conditional approval today gives Coinbase a federal regulatory credential that exists independently of whatever the CLARITY Act ultimately says about yield. The April markup will be the first test of whether the revised text has moved far enough to bring the stablecoin industry's concerns within an acceptable range.
Editor's note: We are committed to accuracy. If you spot an error or have additional information, please email [email protected].
