Warren Demands OCC Records on Nine Crypto Trust Charters by June 1

Senator Elizabeth Warren of Massachusetts, the ranking Democrat on the Senate Banking Committee, sent a six-page letter on May 18 accusing the Office of the Comptroller of the Currency (OCC, the federal regulator that supervises national banks) of issuing at least nine trust charters to crypto companies since December that, in her reading of the National Bank Act, the agency lacked the legal authority to issue. She wants every confidential exhibit, every charter approval letter, and every email between the OCC and the Trump family on Comptroller Jonathan Gould’s desk by June 1.

The letter lands the loudest political punch yet at a charter pipeline that has, almost without public debate, given Ripple, Coinbase, Circle, Paxos, BitGo, Fidelity Digital Assets, Crypto.com, Protego, and Stripe’s Bridge unit a federal supervisor and a single national footprint for custody, payments, lending, and stablecoin work. A tenth applicant in the queue is the Trump family’s World Liberty Trust Company application for the USD1 stablecoin, which Warren also wants documented.

The Letter and the Nine Names

Warren’s letter is addressed to Jonathan Gould, the OCC’s Senate-confirmed Comptroller. It accuses him of approving entities that are, in practice, full-service banks dressed up as fiduciary trust companies. “These companies are effectively crypto banks that want to evade the fundamental safeguards and obligations that come with being a bank,” she wrote, language her staff has been telegraphing to the committee since the December approvals dropped.

The nine firms she names span three categories: de novo applicants building new federal entities, state trust companies converting to a federal charter, and stablecoin-first operations seeking direct issuance authority. The table below is built from the OCC’s own approval roster and each firm’s intended-business filings.

From Trust Company to Bank by Another Name

A national trust charter, in the way the OCC has used it for the past century, lets an entity hold and administer client assets in a fiduciary capacity. It does not, by statute, let that entity take deposits, make loans on its own balance sheet, or operate a payments network. Warren’s argument is that the December and February approvals collapsed that distinction.

Her letter cites four activity categories that, taken together, look like banking with the deposit-insurance bill stripped out:

• Non-fiduciary custody. Holding crypto for customers in a way that resembles a custodial deposit account rather than a trust arrangement.
• Payments facilitation. Moving stablecoin balances between counterparties as a settlement service.
• Lending activity. Extending credit collateralized by digital assets, a function trust companies have not historically performed at scale.
• Stablecoin issuance closely tied to deposit-taking. Accepting dollars in exchange for redeemable tokens, which Warren argues is economically identical to taking demand deposits.

Why the Charter Beats State Licensing

For the firms involved, the upside is mechanical. A national charter preempts the patchwork of money-transmitter licenses across the fifty states and gives the company a single federal supervisor instead of fifty-three. It also opens a path, still contested at the Federal Reserve, to a master account at the central bank, which is the on-ramp to the Fedwire system.

Why the Charter Worries Bank Supervisors

The trade-off, in Warren’s reading, is that a trust charter carries none of the capital, liquidity, or resolution requirements that come with a bank charter. Buchanan Ingersoll’s analysis of the December conditional approvals noted that each approval letter spelled out additional operational conditions, but those conditions are bilateral between the OCC and the firm, not statutory floors a court could enforce.

Five Months, Nine Charters, One Pattern

The pace is the part the headlines have not absorbed. The OCC processed the first wave of conditional approvals on a single day in December and stacked three more in a fortnight in February. A FinTech Weekly tally of charter-related filings counted eleven distinct crypto and payments names in the OCC pipeline by early March, including Morgan Stanley’s digital trust unit and Payoneer.

1. December 12, 2025. Conditional approvals issued in a single batch to Ripple, Circle, BitGo, Fidelity Digital Assets, and Paxos.
2. Early February 2026. Protego’s earlier OCC approval, which had lapsed after the firm failed to open in 2022, is effectively reactivated.
3. February 12, 2026. Bridge, the stablecoin infrastructure unit Stripe acquired in 2024, receives conditional approval.
4. February 18, 2026. Morgan Stanley files for a digital trust charter, the first major Wall Street incumbent into the queue.
5. February 23, 2026. Crypto.com’s conditional approval announcement closes the February cluster.

None of those approvals was a final charter. Each firm still has to satisfy operational and anti-money-laundering conditions before the OCC issues final paperwork, and several of the conversion candidates have to wind down state licenses in parallel. But the conditional approval is the document that lets a firm raise capital, recruit a chief risk officer, and tell counterparties the federal supervisor is real.

The Trump Family Charter Warren Wants Documented

The political pressure point in the letter is World Liberty Financial. The Trump-affiliated DeFi venture filed in January for a national trust charter through a vehicle called WLTC Holdings, with the stated purpose of issuing and custodying its USD1 stablecoin in-house rather than running it through BitGo. USD1 has reached roughly $3.3 billion in circulation in its first year, and the Trump family’s revenue vehicle holds the tokens currently valued in the public filings at around $3.8 billion.

These companies are effectively crypto banks that want to evade the fundamental safeguards and obligations that come with being a bank. The OCC actions pose serious risks to consumers, the safety and soundness of the banking system, and the separation of banking and commerce.

That sentence, from Warren’s letter to Gould, is the spine of her argument and the reason she has demanded every internal communication between OCC officials and any member of the Trump family or their staff. She also wants the WLTC application file. The conflict-of-interest claim, if it gets traction, is what could pull the broader pipeline into a formal congressional review rather than the comment-letter cycle it now sits in. Warren has been positioning on the issue for months: a parallel push to block Ripple from a Federal Reserve master account through CLARITY Act amendments last quarter telegraphed where the May letter was heading.

What World Liberty Has Said

World Liberty has framed the charter as a technical step that consolidates issuance, custody, and redemption under one regulated roof. Critics inside the crypto industry itself have flagged governance questions, including the public complaints from Tron founder Justin Sun about WLFI’s contract architecture, which Warren’s letter does not cite but which sit in the same fact pattern.

The Banking Lobby Is Quietly on Her Side

The American Bankers Association, the Independent Community Bankers of America, and a handful of large state-chartered banks filed comment letters with the OCC during the December approval window arguing that the trust-charter pathway gives crypto firms a regulatory cost advantage their members do not have. Those comment letters did not get the political oxygen Warren’s letter is now generating, but their substance overlaps almost line-for-line.

The banks’ concern is straightforward. A federally chartered bank pays for deposit insurance, holds risk-based capital, files call reports four times a year, and submits to Community Reinvestment Act exams. A national trust bank doing custody, payments, lending, and stablecoin work does none of those things, but operates in the same customer markets. If the trust charter becomes the on-ramp to a Federal Reserve master account, the cost gap widens further.

Inside the OCC, defenders of the approvals point to Interpretive Letter 1188, which lays out the agency’s reading of permissible trust activities. Warren’s reply is that an interpretive letter is not a statute, and that the National Bank Act sets the floor a comptroller cannot redefine through a guidance document.

The June 1 Deadline Sets the Next Move

The deadline matters because of what it forces into the public record. Warren has asked for the approved charter applications in full, the confidential exhibits, the legal analyses the OCC’s general counsel produced before signing the approvals, and the internal communications with the White House and the Trump family. None of those documents are currently public, and several are protected by the OCC’s standard confidentiality rules for bank applications.

If Gould turns over the materials, Warren’s staff has the raw inputs for a hearing or a formal request that the OCC’s Office of Inspector General open a review. If he refuses, the refusal itself becomes the political artifact, and the question shifts from charter policy to executive-branch transparency. Either path puts the trust-charter pipeline on a slower track than the OCC has been running, which is what Warren’s letter is calibrated to do.

President Trump’s January 2025 executive order on digital assets, which directed the OCC and other regulators to remove reputational-risk considerations from supervisory guidance, sits behind every one of these approvals. Pillsbury’s regulatory analysis of the Trump 2.0 digital asset framework traced the line from that order to the December batch of charters. Warren wants the documents by June 1. The OCC has not said whether it will produce them.