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Home»Regulation»Zerohash files second OCC trust bank application
Regulation

Zerohash files second OCC trust bank application

NBTCBy NBTC20/09/2026No Comments4 Mins Read
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Zerohash submitted a second application for a U.S. national trust bank charter on Aug. 19, approximately one month after the Office of the Comptroller of the Currency returned its original filing.

The OCC’s record lists the proposed institution as Zerohash National Trust Bank. It would be based in Asheville, North Carolina, and operate under a holding company structure if approved.

The regulator opened public comments on Aug. 18. Comments must arrive by Sept. 17, giving interested parties 30 days to respond. The public record currently lists the application as received. It does not show an approval, denial or other regulatory decision.

Zerohash narrows its second OCC application

The OCC received Zerohash’s first charter application on March 2 and returned it on July 17. The agency’s public database does not explain which parts of the proposal prompted the return.

A returned application is not the same as a denial on its merits. It generally means the filing did not advance through the OCC’s review process in its submitted form. The regulator assigned the second application a new control number and proposed charter number.

Zerohash previously said the initial return occurred “in coordination with the OCC” and was “not a substantive decision on the merits.” Those statements represent the company’s position. The OCC has not publicly confirmed that characterization.

The company also said its new filing would seek “a more focused approval of national trust activities aligned with our intended rollout timeline.” Neither the publicly available OCC entry nor Zerohash has detailed which activities were removed or narrowed.

An OCC trust charter would expand federal oversight

A national trust bank charter would place the proposed institution under direct OCC regulation. Limited purpose trust banks can provide custody and other approved trust services without operating like full service commercial banks that accept insured deposits and issue conventional loans.

The OCC amended its national bank chartering rule in April 2026. The rule clarified that national trust banks may conduct trust company operations and related activities, including certain nonfiduciary services.

Zerohash already operates through several regulated entities. Its documentation identifies Zerohash Trust Company as a nondepository trust company chartered by the North Carolina Commissioner of Banks. Zerohash LLC also maintains money transmitter licenses and a New York BitLicense.

A national charter could give the company a unified federal supervisory relationship for approved banking activities. It would not automatically authorize every service Zerohash currently provides through separate entities and licenses.

Zerohash supports major financial platforms

Zerohash supplies cryptocurrency trading, custody and stablecoin infrastructure to financial and technology companies. Its disclosed partners include Morgan Stanley, BlackRock, Stripe, Franklin Templeton and Interactive Brokers.

In July, crypto.news reported that Zerohash was providing the infrastructure behind Bitcoin, Ethereum and Solana trading on E*TRADE. Morgan Stanley intends to transfer that service to its own proposed national trust bank later in 2026, although no confirmed transition date has been announced.

Zerohash’s renewed bid also comes amid broader demand for federal crypto charters. As previously reported, the company joined several digital asset businesses seeking OCC trust bank status earlier in 2026.

The OCC has conditionally approved applications from firms including Circle, Ripple, BitGo, Fidelity Digital Assets and Paxos. Conditional approval does not allow a proposed bank to open immediately. Applicants must satisfy capital, governance, compliance and operational requirements before receiving final authorization.

Public comments are the next confirmed step

Interested parties can submit comments through Sept. 17 under OCC control number 2026-Charter-347313. The agency says comments become part of the public record and may include support, objections or requests for specific licensing conditions.

Zerohash is separately defending a California lawsuit filed by former chief compliance officer Edgar Guerra. He reportedly alleges that the company dismissed him after he raised compliance concerns. Zerohash has not been found liable, and the allegations remain unresolved claims.

The litigation and first application’s return may draw scrutiny during the new review. However, the OCC has not publicly connected the lawsuit to its decision to return the earlier filing.

After the comment period closes, the regulator can request more information, impose conditions, approve the application or reject it. The OCC has not published a deadline for reaching a decision.

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