Modern Treasury seeks U.S. trust bank license to conduct stablecoin custody business

Modern Treasury applied for a U.S. trust bank license to provide stablecoin custody services

On October 5, 2026, Modern Treasury submitted an application to the Office of the Comptroller of the Currency (OCC) to establish the "Modern Treasury National Trust Bank." This is a proposed federally regulated, limited purpose trust bank that aims to combine its existing payment and settlement infrastructure with stablecoin and digital asset custody services.

The San Francisco-based payment software company disclosed the application in a press release. If approved, an entity would be created to operate independently under OCC supervision. According to an official announcement, the proposed bank will integrate digital asset custody with a modern payment platform, allowing customers to custody and transfer stablecoins and fiat currencies.

The core content of the application and the scope of the explicit exclusion

The proposed scope of the entity is strictly limited. Modern Treasury confirmed that the bank will not issue loans or issue stablecoins and will not start operations without obtaining full approval and final authorization from the OCC. The company also stated that its existing software and payment services will remain legally and operationally separate from the proposed limited purpose bank.

这一区分对客户和监管机构都至关重要：Modern Treasury 并非寻求成为一家提供全方位服务的商业银行或稳定币发行商，而是希望成为一家在 OCC 监督下有资格持有数字资产的联邦特许托管机构。这种定位将使拟议的银行定位为机构级基础设施，而非消费类产品，主要面向已通过 Modern Treasury 平台处理支付的企业客户群体。

Modern Treasury 表示，其平台已为数百个组织处理了超过 6000 亿美元的支付业务。

作为托管监管边界的信托银行牌照

OCC 颁发的国家信托银行牌照创建了一个受联邦监督的实体，有权为客户持有信托资产，但不具备商业银行的全部放贷或吸收存款权力。对于数字资产公司而言，这种结构提供了一个区别于州级信托牌照的联邦认可托管框架，为机构客户提供针对稳定币和数字资产持有的联邦监管交易对手方。

Modern Treasury 的这一举措出现在更广泛的加密货币和支付公司寻求类似联邦牌照的背景下。据报道，数字资产公司正在推动获取国家信托银行牌照，这一趋势反映了 OCC 监管清晰度的增加以及机构对受联邦监督的托管通道需求的不断增长。

OCC's new banking license approval process shows that between January 2025 and September 18, 2026, a total of 44 applications were received, 27 were approved, 2 were rejected, and 1 was returned, indicating that this is a substantive but highly selective review process.

Why the new custodian layer is critical to institutional stablecoin flows

Stabilizing currency custody is different from stablecoin issuance, it refers to the custody and management of existing stablecoin positions on behalf of customers, while the bank itself does not mince or redeem tokens. For companies that already process fiat through the Modern Treasury payment channel, having federally licensed custody services means they can hold stablecoins in the same regulated relationship, reducing the current need to use separate custodians. fragmentation issues of counterparty parties.

USDC, the benchmark dollar-pegged stablecoin, traded at US$0.999951 as of October 5, 2026, with a market value of approximately US$74.3 billion, and a 24-hour trading volume of nearly US$19.2 billion, highlighting the size of the stablecoin market served by the regulated custody infrastructure.

The timing of the application comes as the U.S. regulatory framework for cryptocurrencies evolves, as federal agencies move towards establishing a clearer regulatory track for digital assets. A federally chartered trust bank provides Modern Treasury with a compliance position unmatched by licensed custodians in the state, especially for customers who are regulated by federal banks or operate in multiple U.S. jurisdictions.

As of October 5, 2026, the Crypto Fear and Greed Index is at a level of 70 (Greedy), reflecting a market environment of widespread risk appetite where announcements about institutional infrastructure often attract continued attention from corporate buyers evaluating custody and settlement options.

Undetermined matters

The application is only submitted and not approved. Modern Treasury made it clear that the proposed bank cannot start operations until the OCC grants final authorization. This process includes a public comment period, capital review and supervisory interviews. The company has not disclosed an expected timetable for approvals, and license statistics released by the OCC indicate that not all applications will be approved: As of September 18, 2026, of the 44 new bank applications received since January 2025, 27 were approved and 2 were rejected.

Prior to authorization, Modern Treasury's existing payment and software platform (which has processed more than $600 billion in transactions) was completely independent of the proposed banking structure. Customers considering future custody services should note that all services described are conditional; no custody products currently exist, and a list of supported stablecoins has not been publicly disclosed.

FAQs: Modern Treasury's National Trust Bank Application

What did Modern Treasury apply for?

Modern Treasury filed an application with the OCC on October 5, 2026 to establish Modern Treasury National Trust Bank, a proposed limited purpose national trust bank under federal supervision.

What is the purpose of the proposed license?

The proposed bank will provide digital asset custody services that allow customers to custody and transfer stablecoins and fiat currencies within the same federally regulated relationship, which is linked to Modern Treasury's payment and settlement services.

Does the application mean that the license has been approved?

No. The application is being reviewed by the OCC and the proposed bank cannot begin operations without receiving full OCC approval and final authorization. Of the 44 new bank applications submitted to the OCC since January 2025, two have been rejected.

When will stablecoin custody be available?

Modern Treasury has not disclosed its target timetable. The OCC's review process includes public comment and capital review phases; a release date has not yet been announced.

What stablecoins will be supported?

The company's announcement did not specify which stablecoins under the proposed bank would be eligible for custody. As of October 5, 2026, this detail has not been publicly disclosed.

The next substantive milestone to watch for is the OCC's release of the application during its new banking license process, which typically triggers a public comment window and marks the start of the formal review clock. For institutional participants weighing a federally supervised stablecoin custody channel, Modern Treasury's application joins a growing queue of fintech and cryptocurrency companies seeking to occupy a regulated neutral zone between traditional banking and U.S. regulators 'accelerating broader cryptocurrency policy shifts in 2026.