Banking and Finance Law Daily Wrap Up, BANKING OPERATIONS—OCC conditionally approves three more national trust bank charters, (Sep 21, 2026)

By Shashi Kant, B.A. LL.B, LL.M.

The Comptroller of the Currency conditionally approved national trust bank charters for Bastion, Catena, and Agora, all proposing stablecoin activities.

The Office of the Comptroller of the Currency has conditionally approved three more national trust bank charters for firms that propose to offer stablecoin and digital asset services. In Corporate Decision 1391, Corporate Decision 1392, and Corporate Decision 1393, all dated September 18, 2026, the agency approved the conversion of Bastion Platforms Trust Company, LLC to a national trust bank and granted preliminary conditional approval to charter Catena Trust Bank, National Association and Agora National Trust Bank. All three banks will be based in New York, New York. The OCC said each must limit its operations to those of a trust company and activities related thereto.

Bastion conversion. Bastion Platforms Trust Company, a New York state trust company wholly owned by the Delaware corporation Bastion Platforms, Inc., applied on March 30, 2026, to convert to a national bank with full fiduciary powers, according to Corporate Decision 1391. The OCC said the converted bank will operate as Bastion Platforms National Trust Company, will not take deposits, and will not be insured by the Federal Deposit Insurance Corporation. The decision lists the bank’s proposed activities as white-label stablecoin issuance, white-label custodial wallet services in a fiduciary capacity, conversion services for custody customers, and issuer services for other regulated stablecoin issuers. The bank will offer custody services only for stablecoins, the OCC said.

Stablecoin issuance is permissible as an operation of a trust company under 12 USC 27(a), the OCC said, because Congress expressly recognized the authority of uninsured national banks to issue stablecoins in the Guiding and Establishing National Innovation for U.S. Stablecoins Act (GENIUS Act). The agency received no comments on the application, it said.

In a separate press release, Bastion said the charter adds OCC supervision to the state licenses it already holds. Chief Executive Officer Nassim Eddequiouaq said in the release that enterprises and financial institutions “can now access stablecoins through a federally regulated counterparty.”

Catena Trust Bank. Catena Labs, Inc. filed an application on May 18, 2026, to charter Catena Trust Bank as a de novo national trust bank without FDIC insurance. The application states that the bank will provide custody, investment management, trust, conversion and clearing, and execution services for fiat currency, investment securities, and digital assets, including GENIUS Act-compliant payment stablecoins. It says the bank will serve customers nationally through application programming interfaces and will offer its services only electronically. The application describes proposed President and Chief Executive Officer Patrick Sean Neville as a co-founder of Circle Internet Financial and the principal architect of USD Coin, and states that Catena Labs is building an AI-native financial institution to serve the emerging agent economy.

Agora National Trust Bank. Agora Atlas Corp., a Delaware corporation based in Jersey City, New Jersey, filed its application on Apr. 17, 2026. The OCC said the bank will focus on dollar-backed stablecoin issuance and reserve maintenance, non-fiduciary digital asset custody, payment and settlement services for custody customers, and fiduciary investment advisory services for enterprise custody customers. Its customers will be exclusively institutional and business participants, according to the decision. Agora Atlas intends to transfer issuance of the AUSD stablecoin from its affiliate Agora Bermuda Limited to the bank, the OCC said. The agency approved that asset purchase as exempt from the quantitative limits, collateral requirements, and low-quality asset prohibition of Regulation W.

Trade group comments. The OCC said it received two comment letters from trade groups representing banks on each of the Catena and Agora applications. According to the decisions, the commenters questioned the agency’s authority to charter the banks and argued that the public was given too little information and too little time to comment. The OCC responded that the proposed activities are permissible and that it followed its established procedures. One commenter on the Catena application asked whether stablecoin issuance amounts to accepting a deposit requiring FDIC insurance. The OCC said stablecoins are not deposits under the Federal Deposit Insurance Act and that Congress confirmed this in the GENIUS Act. On the Agora application, the agency said the Community Reinvestment Act does not apply because the bank will not be an insured depository institution. The OCC said some comments rested on “unfounded assumptions or inaccurate conclusions,” such as the assumption that uninsured national banks have access to the federal safety net. In both decisions it said the concerns raised are not grounds for denial.

Conditions. Each approval requires the bank to conform, cease, or divest its stablecoin issuance and redemption activities as necessary to comply with the GENIUS Act, according to the decisions. Each bank must give the agency 60 days’ notice and obtain a written determination of no objection before significantly deviating from its business plan. The OCC set minimum tier 1 capital at $6 million for Bastion and $10 million each for Catena and Agora, with at least half held in eligible liquid assets. Each must also hold 180 days of operating expenses in eligible liquid assets during its first three years, the OCC said, adding that the conditions are enforceable under 12 USC 1818.

Next steps. The Bastion approval terminates automatically if the conversion is not consummated within six months, absent an extension, according to Corporate Decision 1391. The Catena and Agora approvals expire if capital is not raised within 12 months or the banks do not open within 18 months, the OCC said. Both must satisfy preopening requirements, including an independent external audit and a preopening examination, before the OCC grants final charter approval.

Companies: Agora Atlas Corp.; Agora Bermuda Limited; Bastion Platforms, Inc.; Bastion Platforms Trust Company; Catena Trust Bank

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