Banking and Finance Law Daily Wrap Up, FINANCIAL TECHNOLOGY—OCC conditionally approves Sony Bank’s Connectia stablecoin trust bank, (Jul 8, 2026)

By Colleen M. Svelnis, J.D.

For its first three years, the proposed bank must keep at least $60 million in tier 1 capital and hold separate eligible liquid assets for 180 days of operating expenses.

The Office of the Comptroller of the Currency granted preliminary conditional approval for Sony Bank Incorporated to establish Connectia Trust, National Association, as a New York-based national trust bank to engage in cryptocurrency-related activities focusing on dollar-backed stablecoin issuance, reserve maintenance, custody, transactional services, and fiduciary asset management. The July 2 corporate decision letter gives the proposed bank a path toward a federal charter, but final approval and authorization to commence business will not be issued until Connectia meets all preopening requirements, and the OCC may modify, suspend, or rescind the preliminary approval before then.

Conditions. The OCC conditional approval states that Connectia must restrict operations to trust-company operations and related activities in its business plan and must not meet the Bank Holding Company Act definition of “bank.” It also must conform stablecoin activities to the Guiding and Establishing National Innovation for U.S. Stablecoins (GENIUS) Act and implementing regulations or cease or divest those activities. During the in-organization period and first three years, the bank must give the OCC’s Specialty Asset Supervisory Office at least 60 days’ prior written notice of any significant business-plan or operational change and receive an OCC written no-objection before making the change. The written conditions also require, for the first three years, at least $60.0 million in tier 1 capital; eligible liquid assets equal to the greater of 50 percent of tier 1 capital or $30.0 million; quarterly capital and liquidity assessments; and a separate 180 days of operating expenses in Eligible Liquid Assets without double counting. The OCC said the written conditions are enforceable under federal banking enforcement authority.

The OCC described the proposed operations as focused on dollar-backed stablecoin issuance and reserve maintenance in a nonfiduciary capacity, non-fiduciary custody for holders of bank-issued and selected other stablecoins, transactional services for custody customers, and fiduciary asset management. The transactional services would let customers transfer stablecoins on a closed-loop platform inside a restricted, permissioned network limited to platforms of Sony Group Corporation and its operating subsidiaries. The OCC concluded that all proposed activities are trust-company operations or related activities permissible for a national bank.

Connectia would be headquartered in New York and wholly owned by Sony Bank Incorporated, which the OCC described as a Tokyo-based retail bank founded in 2001 and supervised by the Japanese Financial Services Agency. Sony Bank is wholly owned by Sony Financial Group Incorporated, a diversified financial services company listed on the Tokyo Stock Exchange; Sony Group Corporation owns less than 20 percent of Sony Financial Group.

Sony Bank’s application. On October 6, 2025, Sony Bank submitted its application for OCC approval for the proposed de novo national bank. The application notes that Connectia is planned to engage “in certain digital asset activities” that the OCC has previously found to be permissible under existing national bank legal authorities. These include the issuance of dollar-pegged stablecoins and maintenance of corresponding reserve assets, the provision of non-fiduciary digital asset custody services, and the provision of asset management services as fiduciary to certain affiliates.”

Comment responses. Several industry groups commented on the proposal, including the Independent Community Bankers of America (ICBA) who asserted that Sony is seeking “the benefits of a U.S. bank charter without becoming subject to the full scope of U.S. bank regulations” (Banking and Finance Law Daily, Nov. 7, 2025). Other objections raised by the ICBA is that Connectia’s mission of granting “non-fiduciary custody of digital assets and [issuing] stablecoins to retail customers is outside the scope of the trust bank charter.” ICBA argues that the OCC lacks authority to expand trust powers under Interpretive Letter #1176. Finally, the ICBA submits that Connectia should be subject to the Bank Holding Company Act’s definition of a bank.

The Bank Policy Institute (BPI) and the National Community Reinvestment Coalition (NCRC) also submitted comment letters urging the OCC to deny Sony Bank Incorporated’s application. Both organizations stated that the proposal would establish a national trust bank engaged in stablecoin issuance, digital-asset custody, and related activities without demonstrating that these operations fit within the fiduciary framework required under 12 U.S.C. § 27(a). They also said the application relies on digital-asset structures that have not been fully defined in law or regulation, raises questions about the relationship between a federally chartered trust bank and affiliated commercial entities, and could result in competitive disparities for traditional banks (see Banking and Finance Law Daily, Nov. 13, 2025).

In total the OCC received four comment letters on the proposal—two from bank trade groups and two from community groups. Two commenters questioned whether stablecoin issuance by a national trust bank amounts to accepting deposits requiring deposit insurance. The OCC responded by stating that stablecoins are not deposits under the Federal Deposit Insurance Act and GENIUS Act, payment stablecoins are not subject to Federal Deposit Insurance Corporation insurance, and it is unlawful to represent payment stablecoins as federally insured. The agency also said the GENIUS compliance condition would require Connectia to stop or divest noncompliant stablecoin activities. Commenters also raised supervision and broader policy concerns, but the OCC said it considered relevant issues and those policy objections were not grounds for denial.

Timing. Connectia’s capital-raising method cannot deviate from the application without prior OCC notification; the preliminary approval expires if capital is not raised within 12 months or the bank does not open within 18 months of July 2, 2026. The OCC also said final approval will remain unavailable until all preopening requirements are met.

Attorneys: David E. Teitelbaum (Sidley Austin LLP).

Companies: Bank Policy Institute; Connectia Trust, National Association; Independent Community Bankers of America; National Community Reinvestment Coalition; Sony Bank Incorporated; Sony Financial Group Inc.

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