The Office of the Comptroller of the Currency (OCC) has moved three stablecoin-focused firms closer to federal trust-bank status, but the approvals do not by themselves provide a decisive competitive advantage.
Agora, Catena and Bastion received decisions on 18 September under a similar regulatory framework. The move suggests the OCC is developing a repeatable route for narrow, uninsured national trust banks, although each firm still faces significant legal, operational and commercial hurdles.
Agora and Catena have received preliminary conditional approval to establish new national trust banks. They must complete further work before receiving final approval and permission to begin operating.
Bastion Platforms Trust Company is taking a different route. It already operates under a New York trust charter and has received conditional approval to convert into Bastion Platforms National Trust Company. The conversion must be completed, followed by acknowledgement from the OCC, before it can operate under the national charter.
None of the three decisions gives a firm opening date.
Agora and Catena must notify OCC chartering staff at least 60 days before their planned opening. Their approvals will expire if they do not raise capital within 12 months or open within 18 months.
Bastion’s approval will automatically end if its conversion is not completed within six months, unless the OCC grants an extension because of extenuating circumstances.
Narrow banking model
The three decisions use a shared trust-company structure, but do not give the firms identical permissions.
Each business must restrict its activities to trust-company services and related work. Each must also remain outside the definition of a bank under the Bank Holding Company Act.
The firms will not operate as conventional insured commercial banks. Bastion’s approval states that it will not accept deposits and will not be insured by the Federal Deposit Insurance Corporation. Agora’s proposed institution is also described as an uninsured depository institution, while Catena’s decision classifies it as an uninsured national bank.
Catena’s approval further states that payment stablecoins are not deposits and must not be presented as being insured by the Federal Deposit Insurance Corporation.
Capital requirements differ between the applicants. Agora and Catena must each maintain at least $10 million in tier 1 capital, with liquid assets worth the greater of 50% of tier 1 capital or $5 million.
Bastion must hold at least $6 million in tier 1 capital and liquid assets equal to the greater of 50% of that capital or $3 million. All three firms must review their capital and liquidity every quarter and hold more if their risk profile requires it.
For the first three years operating under the relevant federal charter, each institution must also hold eligible liquid assets equivalent to 180 days of fixed and variable operating expenses in a distressed wind-down. Those assets cannot also be counted towards the liquidity requirement attached to the capital condition.
Agora’s proposed activities include issuing and managing reserves for its dollar-backed stablecoin, AUSD, as well as digital-asset custody, custody-linked payments and settlement, and fiduciary investment advice for institutional and business customers.
The OCC says Agora intends to move AUSD issuance from Agora Bermuda once the bank has been established. That transition would involve transferring the underlying assets and accounts, with the bank acquiring the reserve assets and assuming associated liabilities.
The plan had not yet taken effect by 22 September. Agora’s AUSD product page still identified Agora Bermuda as the issuer and described its reserve management, custody arrangements and partner relationships. Agora has said final approval remains outstanding.
Catena’s proposed bank would provide fiduciary and non-fiduciary custody, fiduciary investment management and trust services. It would also offer conversion, clearing and execution services connected to assets held within those relationships.
Catena’s own announcement presents the business as being focused on artificial-intelligence agents and the companies that use them. That emphasis reflects Catena’s commercial strategy rather than an assessment by the OCC.
Bastion’s proposed federal business is centred on infrastructure for corporate customers. Its approved activities include fiduciary custodial wallets, conversion services for custody clients, white-label stablecoin issuance, and technology and operational services for other authorised issuers.
Bastion says its enterprise customers will be able to use custody, payments and issuance services, while other firms can remain the issuer of record. It describes the conversion as a way to bring together services currently provided through its New York trust charter, other licences and partnerships.
All three applicants must give advance notice of significant changes to their business plans and obtain a written determination of no objection. Compliance, audit, information security and governance requirements also remain to be completed before opening or conversion.
A pathway, not a monopoly
The OCC’s wider record indicates that the approvals are part of a broader pattern rather than an isolated experiment. Its decision index includes digital-asset trust-bank actions involving Bridge, Foris DAX, Coinbase, Laser Digital, Wise and World Liberty, among others.
The agency’s digital-asset applications page also lists further applicants. In August, Comptroller Jonathan Gould said that 23 of 40 new-charter applications received over roughly 18 months involved digital assets. That figure does not mean those applicants will receive approval, but it shows that Agora, Catena and Bastion are part of a larger group.
The OCC’s 2026 trust-bank rule, which takes effect on 1 April, further clarified that national trust banks can conduct permitted non-fiduciary activities alongside fiduciary services. The agency still assesses the legal authority for proposed activities individually, meaning similar applications can receive different outcomes.
Proposed rules implementing the GENIUS Act could create more consistent reserve, capital and liquidity requirements for federal stablecoin issuers. However, those rules remained proposals as of 22 September and did not yet form a final operating regime.
The legal basis for the OCC’s approach is also disputed. The Conference of State Bank Supervisors has challenged the scope of the agency’s trust-charter and pre-emption position and has discussed possible future litigation if states conclude that the charters go beyond the limits of the National Bank Act.
That position does not mean a case has been filed, but it underlines the difference between a repeatable administrative process and settled law.
The approvals give the three firms potential national regulatory reach and allow related services to be brought under one supervisor. They do not provide customers, liquidity, reserve partners, enterprise integrations or a successful launch.
Agora and Catena must still convert preliminary approval into authority to open. Bastion must complete its conversion. All three must maintain capital and wind-down liquidity while convincing customers to adopt their particular combinations of custody, issuance, payments, settlement and control systems.
The federal trust charter remains valuable, but the 18 September decisions suggest it is becoming more of an entry requirement than a complete competitive moat. Distribution, liquidity, reserve relationships and the ability to execute will determine whether the three firms can turn regulatory approval into sustainable businesses.
