Three digital-asset trust charters clear the OCC on $26 million of working capital

Twenty-six million dollars is what the three approvals require in working capital between them. Bastion Platforms, which is converting a New York state charter, must hold $6 million; Agora and Catena Labs, which filed de novo applications, $10 million each ^[8][9][1]. Roman Goldstein, senior director at Klaros Group, told American Banker why the bar sits where it does. "In general, national trust banks have lower capital requirements than insured national banks. That does make them somewhat easier to charter. But the lower capital reflects the absence of credit risk: national trust banks don't lend," he said ^[11]. He also said that "OCC chartering standards don't distinguish between national trust banks and insured national banks" ^[10].

So what the charter buys is an examination relationship over custody and stablecoin issuance, plus whatever conditions the letter attaches. Loss absorption is a separate question, since the entity is not taking credit risk ^[11]. Joel Hugentobler, senior analyst for digital assets and cryptocurrency at Javelin Strategy and Research, told American Banker that "all three are trying to bring digital asset and stablecoin-related activities under a federal framework without becoming traditional deposit-taking banks" ^[2].

The most concrete change in the batch belongs to Agora. It has issued its stablecoin AUSD since 2024 through Agora Bermuda Limited, licensed by the Bermuda Monetary Authority. The OCC decision letter says that once the national trust bank is established the firm "intends to transition the issuance of AUSD from Agora Bermuda to the bank" ^[6][7]. Nick van Eck, Agora's co-founder and chief executive, said in a statement that "the charter will bring Agora's stablecoin, custody and transaction infrastructure under direct federal supervision" ^[15].

The three businesses sitting inside the identical charter type do different things. Bastion is a white-label stablecoin partner for corporations ^[5]. Catena Labs is building for software: "AI agents need a new kind of banking platform," its chief executive, Neville, told American Banker in a statement ^[16]. An allocator comparing the three counterparties has to read the letters to see where they differ.

Bastion's chief executive, Nass Eddequiouaq, said the firm went to the OCC deliberately. "Before GENIUS came into reality, we were working closely with the regulator that had the most know-how of supervising stablecoin issuance," he told American Banker ^[13]. On the CLARITY Act, he said, "Stablecoins already got their CLARITY moment" ^[14].

The case that a conditional trust charter is becoming the standard wrapper here rests on eight approvals across two batches ^[2]. It rests too on applications filed in March, April and May that reached conditional approval inside the same year ^[12], and on the January 2027 date the applicants are working back from ^[3]. The counter-thesis is that none of these is a charter yet, since the working capital is a requirement to get final approval ^[9]. Bastion's figure is $4 million below each de novo number, and Bastion is the one applicant that already held a state trust charter ^[3][8]. American Banker did not report assets under custody or outstanding AUSD balances for any of the three ^[17].