Invest3 publishers2 min readPublished
Modern Treasury asks the OCC for a trust bank to hold its payment clients' stablecoins
Modern Treasury has applied to the OCC for a trust bank to custody stablecoins and fiat for clients of a business that has moved over $600 billion. Approval would let its corporate clients hold and move both kinds of balance through one federally supervised entity.
The Investor · Invest desk
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What happened
- The proposed Modern Treasury National Trust Bank would neither lend nor issue stablecoins, and would run separately from the company's existing payments business.
- Modern Treasury got its stablecoin capability by acquiring Beam in October 2025 and has since folded stablecoins into its payments platform.
- Circle and BitGo already hold final OCC trust approvals and Bastion and Ripple conditional ones, while Kraken parent Payward, Zerohash and Block have applied.
- The Independent Community Bankers of America sued the OCC the week before the announcement, alleging crypto firms get less scrutiny than community banks.
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Why it matters
- decision A treasurer using Modern Treasury would have to split balances between a federally supervised but uninsured custodian and an insured deposit bank, since the charter bars deposits, lending and FDIC insurance.
- exposure Modern Treasury's opening date now depends on the ICBA lawsuit as well as the OCC review, and a finding that the OCC under-scrutinised crypto applicants could reach every firm in its queue.
- precedent With a payments-software vendor filing beside stablecoin issuers, corporate treasurers can expect federally supervised custody to be offered by the firm already running their payment flows.
"We have now fully integrated stablecoins to our payments platform. Pursuing this charter will add direct federally supervised digital asset custody and related services to the infrastructure our customers already use," Marcus said, after calling stablecoins "foundational economic infrastructure for the future" [5]. The company did not say who holds its customers' stablecoins today. The reports describe a payments-infrastructure company, as Crypto Briefing puts it, folding stablecoins into an existing product and wanting the custody leg under its own federal supervision [11].
The terms are narrower than the charter requires. A national trust charter already rules out deposit-taking, lending and FDIC insurance [12], and Modern Treasury has added a promise not to issue a stablecoin [3]. It is choosing not to carry a loan book or put a token of its own into circulation. Holding and moving other people's money, in both forms, is the whole remit [1][2]. The payments business that has moved more than $600 billion [6] stays in the software and payment service provider company, kept apart from what the release calls a "separate, limited-purpose banking entity" offering only OCC-permitted services [7].
Counting both reports, eight other firms are named as having sought OCC trust charters, and four of them hold an approval, two final and two conditional [16]. Modern Treasury filed about 12 months after buying Beam [17]. Nothing goes live until the OCC signs off [8].
The community bankers want that sign-off to be harder to get [13]. "Congress did not create the national trust charter as a side door into the banking system for crypto firms seeking the credibility of a federal bank charter," ICBA President and CEO Rebeca Romero Rainey said [14]. The OCC declined to comment on the litigation [15].
The OCC may approve on the path it already took for Circle and BitGo [10]. Or the ICBA suit slows the charter for everyone in line [13]. Or approval arrives and clients use the trust bank mainly for stablecoins and the dollars needed to settle them, while larger operating cash stays at insured deposit banks [2][12]. I think that last outcome is the likeliest commercial result, even if the first is the likeliest regulatory one. The counter-case is that one supervised counterparty for both rails is worth enough to a treasurer that fiat balances follow the payment flows into custody [2]. I would be wrong if, a year after any approval, Modern Treasury reports fiat in custody that matches or exceeds the stablecoins it holds.
What to watch
- Whether the OCC grants Modern Treasury a conditional approval, and what conditions it attaches to the custody of fiat alongside stablecoins.
- The court's first ruling in the ICBA suit against the OCC, which could change the review standard for every pending trust applicant.
- Decisions on the pending Payward, Zerohash and Block applications, the nearest read on how fast the OCC is clearing payments firms.