Corporate Decision 1370: Coinbase National Trust Company
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Research, not advice. Part of the Bitcoin research archive (October 2026). Claims labelled unverified, contested or fringe are reported, not endorsed; statuses of bills and rules are as of the date checked. Government, court and patent records are public domain; the research notes are CC BY 4.0.
Chartering, Organization and Structure
Corporate Decision #1370
April 2026
April 02, 2026
Michael Nonaka, Esq.
Covington & Burling LLP
850 Tenth Street, NW
Washington, DC 20001-4956
Re: De Novo Charter Application and Request for Residency Waivers (Application) Coinbase
National Trust Company, News York, New York (Proposed)
OCC Control Number 2025-Charter-343449
OCC Control Number 2025-Waiver-343506
Dear Mr. Nonaka:
The Office of the Comptroller of the Currency (OCC) has reviewed your Application to establish
a new national trust bank, which will engage in operations of a trust company and activities
related thereto, including fiduciary activities, with the title of Coinbase National Trust Company,
New York, New York (Bank). The OCC hereby grants preliminary conditional approval of your
charter Application upon determining that your proposal meets certain regulatory and policy
requirements.1
This preliminary conditional approval is granted based on a thorough evaluation of all
information available to the OCC, including the representations and commitments made in the
Application and by the Bank’s representatives. The OCC has also made its decision to grant
preliminary conditional approval with the understanding that the Bank will apply for stock in a
Federal Reserve Bank in accordance with 12 USC 222.2
The OCC has granted preliminary conditional approval only. Final approval and authorization
pursuant to 12 USC 27(a) for the Bank to commence business will not be granted until all
preopening requirements are met. Until final approval is granted, the OCC has the right to
modify, suspend, or rescind this preliminary conditional approval should the OCC deem any
interim development to warrant such action.
Proposed Bank
The Bank would be a wholly owned subsidiary of Coinbase Global, Inc. (Coinbase). Coinbase, a
Texas corporation, was founded in 2012 and is a multinational company known for its U.S.-
1
The OCC also grants the request to waive the director residency requirement for four directors.
2
See also 12 CFR 209.2.
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based crypto exchange for buying, selling, transferring, and storing cryptocurrency and providing
crypto custodian services. The Bank will have its main office in New York, New York, in office
space leased from Coinbase.
The Bank plans to provide digital asset3 custody services as a fiduciary, primarily for
institutional clients, and related activities, including certain transactional services for custody
customers in connection with their custodied assets. Specifically, the Bank’s proposed
transactional services include permitting custody customers to engage in transactions to accept,
hold, and transfer custodied fiat currency and digital assets in the customer’s custodial account.4
The Bank’s proposed transactional services facilitate and are related to the customer’s use of
customers’ custodial accounts. The proposed transactional services will be offered only to
custody customers and relate only to custodied assets. Coinbase custody services are currently
performed by Coinbase Custody Trust Company, LLC (CCTC), a limited purpose trust company
chartered by the New York State Department of Financial Services (NYDFS). Coinbase will
migrate the entirety of this custody business from CCTC to the Bank over the three-year de novo
period.
The Bank will also facilitate its custody clients’ access to certain products that are offered by
Coinbase affiliates, all of which the OCC has previously found to be permissible in relation to
custodial activities and all of which will relate solely to the Bank’s custody customers’ custodied
assets.5 Affiliate services that may be leveraged by the Bank’s custody customers include
Staking, Prime Trading, and Prime Financing. The Bank will offer access to these affiliate
products and services under its authority to act as a finder.6 The Bank will not be providing the
underlying Staking, Prime Trading, and Prime Financing services itself.
The OCC is authorized to charter national banks pursuant to the National Bank Act, 12 USC 21–
27. In 1978, Congress specifically confirmed the OCC’s general authority to charter banks that
limit their operations to those of a trust company.7 The operations of a trust company (i.e., the
3
This letter uses digital assets, cryptocurrency, and crypto interchangeably.
4
The Bank will hold fiat currency held in custody in “for benefit of” (FBO) accounts at third-
party banks.
5
See Conditional Approval No. 1353 (Dec. 12, 2025) (approving a trust bank applications for a
trust bank proposing to engage in staking services for custody customers’ custodied assets);
Corporate Decision No. 1366 (Feb. 13, 2026) (approving a trust bank application for a trust bank
proposing to engage in staking services for custody customers’ custodied assets; to offer a
trading platform to facilitate custody customers buying, selling, and exchanging of custodied
assets with other customer assets; and to offer a lending platform to connect custody customers
willing to lend their custodied assets with other custody customers willing to borrow custodied
assets.).
6
See 12 CFR 7.1002.
7
Congress amended the National Bank Act, 12 USC 27, to add this language in 1978. Financial
Institutions Regulatory and Interest Rate Control Act of 1978, Pub. L. 95-630, § 1504, 92 Stat.
3641, 3713 (1978) (adding this sentence to what is now 12 USC 27(a)).
2
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operations of a trust department of a bank or a limited purpose trust company) typically include
performing fiduciary activities, as well as other activities that may be non-fiduciary in nature,
such as non-fiduciary custody and safekeeping activities.8 Custody and safekeeping activities are
fully within the activities of both trust departments9 and limited purpose trust companies in 1978
and today.10 Thus, the Bank’s proposed digital asset custody services in a fiduciary capacity are
trust company operations.11 Moreover, the transactional and finder services described above are
trust company operations or related thereto based on their close relationship to the fiduciary
custody activities, as described above. All the Bank’s proposed activities also are permissible for
a national bank under 12 USC 92a or 24(Seventh).12
Accordingly, the formation of the Bank is authorized.13
8
See OCC Interpretive Letter No. 1170 (July 22, 2020); OCC Interpretive Letter No. 1078 (Apr.
19, 2007); OCC Interpretive Letter No. 1176 (Jan. 11, 2021). In addition, as of December 31,
2025, OCC-supervised uninsured national trust banks reported a total of $7.0 trillion in assets
under administration. Of that total, $1.7 trillion consisted of custody and safekeeping accounts,
while total fiduciary accounts totaled $5.3 trillion.
9
Id. See Letter from James. J. Saxon, Comptroller of the Currency, (June 25, 1963)
(“safekeeping of the securities in the customer’s portfolio and other custodian services, all of
which will be performed by the bank’s Trust Department in the usual case.”). See also Hearings
before the House of Representatives Committee on Banking and Currency on H.R. 6778, 91st
Congress, Part 3 at 1056 (May 7, 8, and 9, 1969) (including proxy statement of Chase Manhattan
Bank, N.A., from 1969 stating that it provided custody services in its trust department).
10
See, e.g., 1976 S.D. Sess. Laws. ch. 304 § 1(1), (2) 492 (creating South Dakota “trust
company” charter for a “corporation” that sole purpose is the conduct of “trust business” and
among the items defined as part of the trust business is acting as a custodian and holding
property for safekeeping).
11
See 12 CFR 5.20(e)(1)(i). The OCC recently approved charters for national trust banks to
engage in certain activities including digital asset custody activities. See OCC Conditional
Approval No. 1356 (Dec. 12, 2025); OCC Conditional Approval No. 1359 (Dec. 12, 2025).
12
National banks may offer custody in a fiduciary capacity under 12 USC 92a. See 12 CFR 9.13.
National banks possess broad authority to act as intermediary, channeling funds from one source
and making them available to another source. See OCC Interpretive Letter No. 948 (Oct. 23,
2002); see also Auten v. U.S. Nat’l Bank of New York, 174 U.S. 125 (1899). In facilitating the
movement of funds on behalf of its custody customers, the Bank would be performing this
financial intermediary role in service of its trust operations, specifically, in facilitating custody
customers’ transfer custodied assets in and out of their custody accounts. See OCC Interpretive
Letter No. 1188 (Dec. 9, 2025). Another expression of a national bank’s role as intermediary is
its authority to act as a finder. See 12 CFR 7.1002. In facilitating its custody customers’ access to
products offered at Coinbase affiliates, including staking services and financing services relating
to assets under custody, the Bank will be operating within its established authority to act as a
finder.
13
In 2003, the OCC amended 12 CFR 5.20(e)(1)(i) to address a subset of national bank, namely
special purpose banks that conduct at least one of the “core banking functions.” As evidenced by
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Public Comments and Analysis
The OCC received five comments in connection with the Application: two comments from trade
groups representing banks and three community groups. Four of the comments discuss the
OCC’s authority to charter the Bank, asserting, among other things, that the proposed activities
do not align with OCC precedent with respect to fiduciary activities conducted by national trust
banks. The OCC is authorized to charter national banks pursuant to the National Bank Act, 12
USC 21-27. As explained herein, the proposed activities are permissible for a national trust bank.
Three of the commenters assert that the OCC and the Bank did not provide an appropriate
amount of information or give a sufficient amount of time for the public to have an opportunity
to meaningfully comment on the Application. The Bank filed all required publicly available
information on a timely basis. In considering the Bank’s identification of public information and
request for confidential treatment of specific information pursuant to 12 CFR 5.9(c), the OCC
followed its established policies and procedures. Although the commenters raised insufficiency
of public information, they were nonetheless able to provide voluminous comments on the
Application. The OCC has received sufficient information to make an informed decision
regarding the Bank’s Application, consistent with established agency policy and procedures,
applying relevant statutory requirements and regulatory factors.
One commenter discusses potential issues and arguments related to stablecoin issuance.
However, the Bank does not propose to issue stablecoins, so the issues and argument are
irrelevant to the Application.
One commenter discusses whether the Bank may engage in brokerage activity for digital assets
that are securities for purposes of Federal securities laws that would subject the Bank to
registration requirement under the Securities Exchange Act of 1934,14 the Investment Company
Act of 1940,15 the Investment Advisers Act of 1940,16 or require exemption from registration
under Regulation R.17 To the extent the Bank’s activities implicate the Securities Exchange Act
of 1934, the Investment Company Act of 1940, the Investment Advisers Act of 1940, or
Regulation R, the OCC will monitor for compliance, as applicable.
the 2003 rulemaking to amend 12 CFR 5.20(e)(1)(i) and the OCC’s chartering and supervision of
national trust banks, this amendment did not interpret or otherwise affect the OCC’s
longstanding authority to charter a national bank limited to operations of a trust company and
activities related thereto under 12 USC 27(a). See 68 Fed. Reg. 71026 (Dec. 17, 2003). The OCC
promulgated changes to 12 CFR 5.20, effective April 1, 2026, to more closely align with the
statutory authorization. See 91 Fed. Reg. 9977 (March 2, 2026).
14
15 USC 78a et seq.
15
12 USC 80a-1 et seq.
16
12 USC 80b-1 et seq.
17
17 CFR 247.
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Three commenters discuss the history of enforcement actions against affiliates of the Bank. To
the extent that deficiencies underlying enforcement actions discussed by the commenters relate
to the planned activities of the Bank, the relationships are attenuated and would be best evaluated
as part of the supervisory process rather than as a basis for denial of the application. Moreover,
among other factors, when considering an application to establish a de novo national bank, the
OCC considers the competence of management, whether the bank will be operated in a safe and
sound manner, and the organizers’ familiarity and ability to comply with laws and regulations.
The OCC’s review of the Application found favorably with respect to these factors. The OCC
routinely examines for compliance with applicable laws and regulations and evaluates whether
institutions demonstrate their ability to comply with applicable laws. These requirements include
the establishment of a robust program to ensure compliance with the requirements of the Bank
Secrecy Act (BSA) and Office of Foreign Assets Control (OFAC), including policies and
procedures approved by the Board of Directors and a program that ensures personnel are
appropriately trained in BSA/AML/OFAC procedures. The OCC will ensure that the Bank
continues to comply with all applicable requirements through the supervisory process.
Three commenters discuss that the Community Reinvestment Act or Community Reinvestment
Act-like requirements should apply to the Bank; however, the Community Reinvestment Act is
not applicable to the Bank as a matter of law. The Community Reinvestment Act applies to
regulated financial institutions, and regulated financial institutions is defined in 12 USC 2902(2)
to mean an insured depository institution as defined in 12 USC 1813. Insured depository
institution means any bank or savings association the deposits of which are insured by the
FDIC.18 The Bank will not be an insured depository institution. No Community Reinvestment
Act-like requirements apply to entities other than insured depository institutions. Since no
Community Reinvestment Act-like requirements apply, such requirements are not relevant to the
factors the OCC may consider for approval.
Several commenters raised other issues pertaining to the OCC’s ability to appropriately supervise
the Bank or broader policy concerns. Commenters made arguments concerning (1) the OCC’s
ability to resolve the Bank in instances of failure, (2) criticisms of the current cryptocurrency and
stablecoin framework and insufficiencies related to potential fraud and financial losses, and the
absence of liquidity standards, reserve requirements, or consumer protection, (3) the importance
of the separation of banking from commerce to maintaining safety and soundness of the financial
system, and (4) safety and soundness concerns related to the Bank’s reliance on Coinbase
enterprise systems and shared services and the financial sustainability of the Bank’s business
model. The OCC is experienced in supervising and regulating national banks, including national
banks engaging in new or novel activities. In the course of reviewing an application, the OCC
considers all of the items above as many specifically tie to or relate to factors or considerations
in 12 CFR Part 5.19 The OCC reviewed the Bank’s Application and has considered whether the
Bank’s business model can be expected to achieve and maintain profitability and found
favorably.20 The OCC regulates and supervises all entities in its jurisdiction in accordance and
18
See also 12 CFR 25.11(c)(3).
19
See 12 CFR 5.20(f)-(h).
20
12 CFR 5.20(f)(2)(i)(D).
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consistent with applicable law. The OCC has a supervisory unit specifically responsible for novel
banks consisting of examiners with specialized experience in novel activities. The OCC has over
160 years of experience supervising and regulating a variety of financial institutions and
financial activities that have continuously evolved. The OCC has the ability to supervise the
Bank to ensure compliance with applicable laws and regulations. Moreover, aspects of the
comments are premised on unfounded assumptions or inaccurate conclusions (e.g., that
uninsured national banks have access to the “federal safety net”). Many of these criticisms reflect
the framework that Congress has established for supervision of the banking system, such as
uninsured national banks generally not being subject to the activity restrictions established by the
Bank Holding Company Act.21 The policy concerns raised by the commenters are not grounds
for denial of the Application.
With respect to concerns related to the OCC’s ability to resolve uninsured entities, the OCC has
a regulation pertaining to the resolution of uninsured national banks that outlines the receivership
process for uninsured entities.22 The OCC, through its application review, also considers, as
appropriate, potential considerations related to receivership or resolution. The OCC has the
capability to resolve an uninsured national bank.
Fiduciary Activities
The OCC approves the Bank’s plan upon commencing business to exercise fiduciary powers
pursuant to 12 USC 92a and 12 CFR 5.26. This approval constitutes a permit to exercise the
fiduciary powers requested in your Application under 12 USC 92a and 12 CFR 5.26(e)(4).
Specifically, the Bank will provide cryptocurrency custody in a fiduciary capacity. The Bank’s
proposed fiduciary custody activity is permitted under 12 USC 92a, which states that fiduciary
capacity may include “any other fiduciary capacity in which State banks, trust companies, or
other corporations which come into competition with national banks are permitted to act under
the laws of the State in which the national bank is located.” The Bank is located in the state of
New York and New York state law permits state trust companies to provide cryptocurrency
custody in a fiduciary capacity. The Bank’s provision of custody services will be subject to
fiduciary duties and standards of behavior.
Conditions
This preliminary conditional approval is subject to the following condition(s):
1. The Bank must limit its operations to those of a trust company and activities related
thereto, as specifically stated in the business plan. The Bank must not meet the definition
of “bank” under section 2(c)(1)-(2) of the Bank Holding Company Act.
2. If and to the extent necessary, the Bank must conform its proposed activities to comply
21
See, e.g., 12 USC 1841(c) (definition of bank excluding uninsured banks that do not both
accept demand deposits and make commercial loans).
22
12 CFR 51.
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with the GENIUS Act (12 USC 5901 et seq.), any implementing regulations, and any
other applicable laws and regulations that take effect in the future, such compliance to be
determined in the sole discretion of the OCC.
3. The Bank shall: (i) give the Novel Bank Supervisory (NBS) Office at least sixty (60)
days prior written notice of its intent to significantly deviate or change from its business
plan or operations (if such deviation is the subject of an application filed with the OCC,
no separate notice to the supervisory office is required); and (ii) shall obtain the OCC’s
written determination of no objection before the proposed Bank engages in any
significant deviation or change from its business plan or operations. For the avoidance of
doubt, a material deviation includes changes to the proposed Bank’s risk and operating
limits, as detailed in its business plan, including those established to ensure that the Bank
will maintain a highly liquid balance sheet. The OCC may impose additional conditions it
deems appropriate in a written determination of no objection to a bank’s notice. This
condition shall remain in effect throughout the Bank’s in organization period and during
the Bank’s first three years of operation.
4. The Bank must maintain a minimum of $60 million in tier 1 capital of which the greater
of at least 50 percent of its tier 1 capital or $30 million must be held in Eligible Liquid
Assets.23 The Bank must assess the appropriateness of its level of capital and liquidity on
a quarterly basis and hold such higher amounts of capital and liquidity as it determines
necessary to support the bank’s risk profile, business strategies, and future growth
prospects, and to provide a cushion against unexpected losses. This condition will remain
in effect during the Bank’s first three years of operation.
5. The Bank must maintain 180 days of operating expenses24 in Eligible Liquid Assets. This
amount must not be double counted with the Eligible Liquid Assets held to comply with
the foregoing condition. This condition will remain in effect during the Bank’s first three
years of operation.
23
The term “Eligible Liquid Assets” means only Liquid Assets that exceed the aggregate amount
of all deposits, borrowed funds, and other liabilities on the Bank’s balance sheet that reflect an
obligation to repay funds to any party. The term Eligible Liquid Assets shall not include any
assets that are pledged in any manner, nor any assets that are not free and kept free from any lien,
encumbrance, charge, right of set off, credit or preference in connection with any claim against
the Bank. The term “Liquid Assets” means: (i) unencumbered cash; (ii) deposits at insured
depository institutions with a maturity of 90 days or less; (iii) United States government
obligations maturing within 90 days or less; and (iv) such other assets as to which the Bank has
obtained a written nonobjection from the OCC. The term Eligible Liquid Assets shall not include
any obligation of any affiliate.
24
The minimum 180 days of operating expenses must include all fixed and variable operating
expenses that would apply in a distressed, wind-down scenario and need not include expenses
that would apply only in a normal operating scenario, such as expenses related to research and
development.
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6. Prior to the appointment of any individual to the position of “senior executive officer,”
as defined in 12 CFR 5.51(c)(4), or the appointment of any individual to the board of
directors, the proposed Bank must submit to the OCC the information described in the
“Changes in Directors and Senior Executive Officers” booklet of the Comptroller’s
Licensing Manual, and receive a letter of no objection from the OCC. For purposes of
this condition, “senior executive officer” also includes the Chief Compliance Officer, the
Bank Secrecy Act Officer, the Chief Technology Officer, the Chief Information Security
Officer, the Chief Trust Officer, and any fiduciary officers or employees designated for
that purpose. This information is required by the authority of 12 USC 1818(b) and 12
CFR 5.20(g) and does not require the OCC to review or act on any such information
within ninety (90) days. This condition will remain in effect throughout the Bank’s in
organization period and during the Bank’s first three years of operation.
The conditions of this approval are conditions “imposed in writing by a Federal banking agency
in connection with any action or any application, notice, or other request” within the meaning of
12 USC 1818. As such, the conditions are enforceable under 12 USC 1818.
As a de novo national bank, the Bank must also meet the following requirements prior to
requesting its preopening examination and before the OCC will grant final charter approval
pursuant to 12 USC 27(a):
1. The Bank’s financial statements must be prepared on an accrual basis according to
generally accepted accounting principles.
2. The Bank must engage an independent, external auditor to perform an audit according to
generally accepted auditing standards of sufficient scope to enable the auditor to render
an opinion on the financial statements of the Bank, taken as a whole. The audit period
shall commence on the date that the organizing group forms a body corporate and may
end on any calendar quarter-end no later than 12 months after the Bank opens. The OCC
expects that such audits will be performed annually for at least three years following
commencement of operations. Engagement of an auditor will be verified during the
preopening examination (see the “Charters” booklet, Internal and External Audits
discussion).
3. The directors of the Bank must own qualifying shares in conformance with 12 USC 72
and 12 CFR 7.2005.
4. The Bank must have adequate fidelity bond coverage in accordance with 12 CFR 7.2013,
which lists four factors the directors should consider to determine adequacy (see the
“Charters” booklet, Fidelity and Other Insurance discussion).
5. The President, or the person serving in the function of President, must serve as a member
of the board of directors.
6. Each person who, together with his or her related interests, subscribes to 10 percent or
more of the initial stock offering must submit a biographical and financial report for
review to the Chartering, Organization & Structure staff prior to acquisition of the shares
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and staff must have no objection to each person before purchasing the shares. After
opening the Bank, the Bank will comply with the requirements of 12 CFR 5.50.
7. Management and the Board must maintain policies and procedures that address all OCC
regulations and will guide the Bank’s operations in a safe and sound manner.
Management and the Board are responsible for establishing a robust program to ensure
compliance with the requirements of the Bank Secrecy Act (BSA) and Office of Foreign
Assets Control (OFAC), including policies and procedures approved by the Board of
Directors and a program that ensures personnel are appropriately trained in
BSA/AML/OFAC procedures. All policies and procedures must be completed no later
than the date of the applicant’s request for a preopening examination. In addition, the
board of directors must review and adopt the policies and procedures at its first meeting.
The board of directors is responsible for regular review and modification of policies and
procedures and for assuring continuous compliance with them.
8. The Bank must have a security program in place that complies with the “Interagency
Guidelines Establishing Standards for Safeguarding Customer Information” specified at
12 CFR 30, Appendix B (Appendix B).
9. The Bank must submit to the Novel Bank Supervision Office for review, and prior
written determination of no supervisory objection, a complete description of the Bank’s
final information systems and operations architecture as well as the information systems
risk assessment and management plan. This should include a schematic drawing.
10. The Bank must ensure that all other required regulatory approvals have been obtained.
11. A letter must be submitted to the Chartering, Organization and Structure staff at least 60
days before the Bank is scheduled to open, notifying the OCC that all conditions and
requirements necessary to receive a national bank charter have been met, requesting a
preopening examination, and providing the anticipated opening date.
The manner in which capital is raised must not deviate from that described in the application
without prior written OCC notification. If the capital for the Bank is not raised within 12 months
or if the Bank is not opened for business within 18 months from the preliminary conditional
approval date, this approval expires. The OCC is opposed to granting extensions, except under
the most extenuating circumstances and when the OCC determines that the delay is beyond the
applicant’s control. The organizers are expected to proceed diligently, consistent with their
Application, for the Bank to open for business as soon as possible.
Organizers, Directors and Officers
The OCC poses no objection to the following persons serving as executive officers, directors,
and/or organizers as proposed in the Application:
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Name Title
Rick Schonberg Director and Chief Executive Officer
Alesia Haas Director and Chief Financial Officer
Gregory Tusar Director
Paul Grewal Director
Dana Wagner Independent Director
Brian Dong Independent Director
Robert Easton Independent Director
Prior to the Bank’s opening, the Bank must obtain the OCC’s prior written determination of no
objection for any additional organizers or executive officers, or directors appointed or elected
before the person assumes the position.
Waiver of Residency Requirements
The OCC also granted your request to waive the residency requirements of 12 USC 72 for Alesia
Haas, Brian Dong, Dana Wagner, and Paul Grewal to serve as members of the board directors of
the Bank. This waiver is granted based upon a review of all available information, including the
filing and any subsequent correspondence and telephone conversations, and the Bank’s
representation that this waiver will not affect the board’s responsibility to direct the Bank’s
operations in a safe, sound, and legal manner. The OCC reserves the right to withdraw or modify
this waiver and, at its discretion, to request additional information at any time in the future.
Organizing Steps and Pre-Opening Requirements
The “Charters” booklet in the Comptroller’s Licensing Manual provides guidance for organizing
your bank. The booklet is located at the OCC's web site: https://www.occ.gov/publications-and-
resources/publications/comptrollers-licensing-manual/files/charters.pdf. The booklet contains all
the steps you must take to receive final approval.
As detailed in the booklet, you may establish the corporate existence of and begin organizing the
Bank as soon as you adopt and forward Articles of Association and the Organization Certificate
to the Chartering, Organization and Structure office for review and acceptance. The Bank may
not begin the business of banking until it fulfills all requirements for a bank in organization and
the OCC grants final approval.
As a “body corporate” or legal entity, you may begin taking those steps necessary for obtaining
final approval. “In Organization” should follow the bank’s name in all official documents,
stationery, advertisements, and other references to the Bank until it opens for business.
Enclosed is a pre-opening checklist for new national banks. The Bank must meet the conditions
and requirements above before it is allowed to commence business, and the Board of Directors
must ensure that the applicable policies and procedures are established and adopted before the
Bank begins operation.
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Conclusion
This approval and the activities and communications by OCC employees in connection with the
filing do not constitute a contract, express or implied, or any other obligation binding upon the
OCC, the United States, any agency or entity of the United States, or any officer or employee of
the United States, and do not affect the ability of the OCC to exercise its supervisory, regulatory,
and examination authorities under applicable law and regulations. The foregoing may not be
waived or modified by any employee or agent of the OCC or the United States.
Our approval is based on the bank’s representations, submissions, and information available to
the OCC as of this date. The OCC may modify, suspend, or rescind this approval if a material
change in the information on which the OCC relied occurs prior to the date of the transaction to
which this decision pertains.
If you have any questions, please reach out to your points of contact for Chartering,
Organization, and Structure.
Sincerely,
//signed//
Stephen A. Lybarger
Senior Deputy Comptroller
Chartering, Organization
and Structure
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