OCC Sets $60 Million Capital Floor for Coinbase National Trust

By Tom Whitfield

The Office of the Comptroller of the Currency set a $60 million Tier 1 capital minimum for Coinbase National Trust Company in an April 2 preliminary decision. The action authorizes the company to "safeguard cryptocurrency for clients while acting in a fiduciary role," subject to that role's duties and conduct requirements.

The April decision also requires eligible liquid assets equal to the greater of 50% of Tier 1 capital or $30 million. Coinbase must maintain a separate pool covering 180 days of operating expenses and complete quarterly assessments during its first three years.

What did the April decision authorize?

The OCC limits Coinbase National Trust Company to "trust-company operations and related activities" in its business plan. This confines the authorized activity to the approved trust-company model rather than an open-ended operating mandate.

For clients, that structure places cryptocurrency safeguarding within a fiduciary custody framework. For Coinbase, it makes any significant departure from the approved plan subject to the decision's notice and written non-objection process.

What must Coinbase maintain?

At the $60 million capital floor, 50% equals $30 million, so the two components of the greater-of liquidity test converge. Above that floor, the capital-linked requirement rises with Tier 1 capital, while $30 million remains the fixed alternative.

Coinbase must maintain a separate pool of eligible liquid assets covering 180 days of operating expenses during its first three operating years. Those assets cannot also count toward the capital-related liquidity buffer, so the company must satisfy two distinct liquidity tests.

The tests use different reference points. Tier 1 capital sets the minimum capital base, while the liquidity rules govern assets held against that base and against 180 days of costs. Because the expense test follows operating costs rather than a fixed dollar amount, Coinbase must size the separate pool to its expense base during the first three years.

What happens during the first three years?

Coinbase must complete quarterly capital and liquidity assessments during its first three years of operation. The 180-day operating-expense reserve requirement applies during the same period. Together, these provisions create recurring supervisory checkpoints rather than a one-time certification.

What changes require prior notice?

Significant changes to the business plan or operations require at least 60 days' prior written notice and the OCC's written non-objection. The condition applies during the in-organization period and the first three years of operations.

The pairing gives planned custody or operating changes a defined advance review window. Written non-objection remains required before implementation, so material changes cannot bypass the OCC process.

How do the April and November milestones differ?

On April 2, the OCC approved the application through a preliminary decision containing the capital, liquidity and notice conditions. Coinbase National Trust Company's charter became effective Nov. 6, and Coinbase announced final approval Nov. 9.

The sequence matters for interpreting the approval: April supplied the quantitative and procedural terms, while November established the charter timeline. The Nov. 6 effective date and Nov. 9 announcement do not replace the April conditions. The charter's effective date and fiduciary custody scope mark separate milestones from its minimum-capital, liquidity and notice provisions.

What operational constraints follow?

For Coinbase, the $60 million Tier 1 minimum anchors the balance-sheet commitment required under the OCC's preliminary decision. The two liquidity pools also limit how eligible assets can support capital and operating needs, because assets serving the 180-day reserve cannot also count toward the capital-related buffer.

The decision also confines activity to trust-company operations and related activities. Any significant plan or operational change during the first three years triggers the 60-day notice and written non-objection process. During that window, Coinbase will face quarterly assessments, the 180-day reserve requirement and advance notice for every significant proposed change.