OCC clears World Liberty to issue USD1 inside a national trust bank

What happened

The Office of the Comptroller of the Currency granted preliminary conditional approval on 14 August 2026 to charter World Liberty Trust Company, National Association, of Bay Harbor Islands, Florida, a wholly owned subsidiary of WLTC Holdings LLC and charter number 25407. The decision is Corporate Decision #1385, a nineteen-page letter signed by Stephen A. Lybarger, Senior Deputy Comptroller for Chartering, Organization and Structure, and addressed to the applicant's chief compliance officer. It says that 'The OCC hereby grants preliminary conditional approval of your charter application upon determining that your proposal meets certain regulatory and policy requirements', and that final approval to commence business under 12 USC 27(a) 'will not be granted until all preopening requirements are met'. The bank's proposed activities are dollar-backed stablecoin issuance, redemption and reserve maintenance in a nonfiduciary capacity, digital asset custody as a fiduciary, and conversion of approved stablecoins into USD1 for custody customers only. The letter states that the bank plans to issue USD1 to institutional clients nationwide, 'assuming this role from BitGo Bank & Trust, National Association (BitGo), the current exclusive issuer and custodian for USD1'. Seven conditions attach, enforceable under 12 USC 1818: the bank must limit itself to trust company operations and must not meet the definition of a bank under the Bank Holding Company Act; it must conform, cease or divest its stablecoin activities to comply with the GENIUS Act and any implementing regulations, in the OCC's sole discretion; it must give sixty days notice and obtain a written no objection before deviating from its business plan; it must hold at least $20m of tier 1 capital, with the greater of half of that or $10m in eligible liquid assets, and separately 180 days of operating expenses in the same form; it must clear senior executive officers and directors with the OCC; and it must retain an internal audit manager independent of the functions audited. The approval expires if capital is not raised within twelve months or the bank does not open within eighteen. The OCC posted no news release and, CNBC reported, declined to comment. World Liberty Financial's chief executive Zach Witkoff said in a statement that 'We welcome continuous scrutiny from Federal regulators for many years to come'. Senator Elizabeth Warren said, in a statement reported by CNBC, that 'President Trump is now the first President in history to approve, operate, and supervise his own bank'.

Why it matters

The part no report carried is on the second and third pages, and it is a transfer rather than a launch. USD1 already exists and is already issued out of a national trust bank; BitGo Bank & Trust is described by the OCC as its current exclusive issuer and custodian. What the charter does is move that seat to a bank owned by the token's own sponsor, and the letter clears the balance-sheet mechanics of the move inside the chartering decision. After the bank is established it intends to acquire the USD1 reserve assets and assume the associated liabilities from BitGo. The OCC records that this 'could be a covered transaction' under section 23A of the Federal Reserve Act by the attribution rule of Regulation W, and then approves it in writing as exempt under 12 CFR 223.42(i), the new-bank exemption, from the quantitative limits, the collateral requirements and the low-quality asset prohibition. An entire stablecoin reserve changing hands between affiliates is a Regulation W question, and it has now been answered once. The legal weight is carried by statute rather than by the agency's own precedent. On whether a stablecoin is a deposit, the OCC says that under the GENIUS Act Congress clearly acknowledged the authority of national trust banks to issue stablecoins, that payment stablecoins are excluded from the definition of a deposit and from FDIC insurance, and that an uninsured national bank is a federal qualified payment stablecoin issuer. From that follows the answer to four commenters on the Community Reinvestment Act: it 'is not applicable to the Bank as a matter of law', because the Act reaches insured depository institutions and this bank will not be one. So the charter delivers federal supervision and a national footprint without deposit insurance and without the community obligations that attach to insured banks. The Federal Reserve appears twice, pointing opposite ways. The approval is granted 'with the understanding that the Bank will apply for stock in a Federal Reserve Bank in accordance with 12 USC 222', which is the membership route. But in answer to a commenter who asked that the bank be barred from a master account, the OCC records that 'To date, the Bank also does not plan to seek access to a Federal Reserve Master Account, and the Federal Reserve determines access to Federal Reserve Master Accounts'. A stablecoin issuer inside the national banking system, holding its reserve, without a settlement account at the central bank, is the arrangement this decision authorises, and the question of who gets a master account is the one the industry has been litigating from the other direction.

What is not settled

This is a preliminary approval and the bank does not exist yet. Capital has to be raised, an external auditor engaged, directors' qualifying shares taken up, policies adopted and a preopening examination requested at least sixty days before opening, and the OCC reserves the right to modify, suspend or rescind the approval if anything material changes. Nothing in the letter says when the USD1 reserve and liabilities would move from BitGo, on what valuation, or what happens to BitGo's role if the transfer stalls. The letter carries no figure for USD1 in issue; the reports put it at about $4bn and fourth largest, which is their number and not the Commission's. On the conflict-of-interest objections, the OCC answered on scope rather than on merits: four commenters raised the president and his family, three suggested the bank might be favoured because the Comptroller is a presidential appointee, one raised the Emoluments Clause and several asked for a review by the Committee on Foreign Investment in the United States. The agency replied that approvals of this kind are made under authority delegated to career staff, that the bank will not issue, custody or deal in WLFI tokens, and that World Liberty Financial, Inc., is not a party to the application, so those questions are outside its review. Whether that is the right perimeter is a matter for Congress rather than the OCC, and Senator Warren and colleagues have said they will introduce a bill to bar senior officials from owning or controlling a bank, which had not been introduced when this was written. Two things in the document do not line up and are worth recording because a reader can check them. Page 4 says the passivity commitments came 'in a letter dated July 13, 2026'; page 12 says the approval rests on 'the passivity commitments dated June 13, 2026', and the three signature blocks in the exhibits carry an empty Dated line. Footnote 8 gives Paxos's conditional approval as 'Dec. 12, 2026', a date that has not happened, where the neighbouring footnote places the same batch of approvals in December 2025. Nothing turns on either.