On December 8, the OCC published a speech made by Comptroller of the Currency Jonathan V. Gould at an industry policy summit on his commitment to chartering new banks, aligning the importance of de novo chartering with novel technologies like digital assets. From 2011 through 2024, the OCC received fewer than four charter applications annually. However, in 2025, the agency reported receiving 14 de novo charter applications, including applications from entities involved in digital or fintech activities, and suggested such entities should be entitled to a pathway to become banks, assuming all charter requirements can be met. Specifically, the comptroller stated that “it is important that we do not confine banks, including current national trust banks, to the technologies or businesses of the past.”

The comptroller’s speech noted that while some proposed activities by new charter applicants, particularly those in the digital asset and fintech sectors, might at first appear novel for national trust banks, electronic custody and safekeeping services have been standard practice for decades. The agency asserted there is no justification for treating digital assets differently and pointed to how New York and South Dakota have already allowed state trust companies to provide digital asset services to their customers.