Corporate Decision 1391: Bastion Platforms Trust Company converts to national bank
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Chartering, Organization and Structure
Corporate Decision #1391
September 2026
September 18, 2026
Michael Nonaka Via encrypted email
Covington & Burling LLP
850 10th Street NW
Washington, DC 20001
Re: Application by Bastion Platforms Trust Company, LLC, New York, New York (Bank or
BPTC) to Convert to an Uninsured National Trust Bank.
OCC Control Number 2026-Conversion-345413
OCC Control Number 2026-Waiver-345476 (collectively, Application)
New Charter Number 27198
Dear Mr. Nonaka:
The Office of the Comptroller of the Currency (OCC) hereby conditionally approves the
application filed by Bastion Platforms Trust Company, LLC (BPTC), New York, New York, a
New York state trust company, to convert to a national trust bank, which will engage in
operations of a trust company and activities related thereto, including fiduciary activities. The
OCC hereby grants conditional approval of the Application upon determining that the proposal
meets certain regulatory and policy requirements.1 This 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 made its
decision to grant 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 converted bank will operate under the title of Bastion Platforms National Trust Company
(Bank) under OCC Charter Number 27198. The Bank’s main office will be located at 216
Bowery, 5th Floor, New York, New York 10016. The Bank will not take deposits and will not be
insured by the Federal Deposit Insurance Corporation.
Proposed Bank
On March 30, 2026, BPTC filed an application to convert to a national bank and operate will full
fiduciary powers. BPTC also requested a citizenship waiver for one director.
BPTC is a wholly owned subsidiary of Bastion Platforms, Inc. (BPI), a privately-held Delaware
corporation. The Bank’s proposed activities include white-label stablecoin issuance, white-label
1
The OCC also grants the request to waive the citizenship requirement for one director.
2
See also 12 CFR 209.2.
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custodial wallet services in a fiduciary capacity, conversion service for custody customers, and
issuer services to other regulated stablecoin issuers.
A state bank, including a state trust company, may convert into a national bank under 12 USC 35
with the approval of the OCC.3 BPTC is a state trust company organized under New York law
and is authorized to convert to a national bank under 12 USC 35 and 12 CFR 5.24.
Twelve USC 35 provides that any bank incorporated by special law of any state or organized
under the general laws of any state may convert into a national banking association provided
that: 1) it has capital sufficient to entitle it to become a national bank, 2) the conversion is
approved by a vote of the shareholders owning not less than fifty-one percent of the stock, 3) the
bank obtains the approval of the Comptroller, 4) the name of the new association includes the
word “national,” and 5) the conversion is not in contravention of state law.
The OCC concludes that the conversion meets the criteria in 12 USC 35. First, the conversion
would not be in contravention of applicable law. BPTC also meets the other criteria in section 35,
including shareholder approval. Thus, the conversion is authorized under section 35. In addition,
the OCC has reviewed the factors applicable to the conversion under 12 CFR 5.24 and 5.13(b)
and found them consistent with approval.
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 and activities related thereto. 4 As
BPTC is currently a New York trust company, its current authorized activities are already those
of a trust company and would be continued after the conversion. The operations of a trust
company (i.e., the 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 are non-fiduciary
in nature, such as non-fiduciary custody and safekeeping activities. 5 Custody and safekeeping
activities were fully within the activities of both trust departments 6 and limited purpose trust
3
See, e.g., OCC Conditional Approval No. 1358 (Dec. 12, 2025).
4
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)).
5
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 March 31, 2026, OCC-supervised uninsured national
trust banks reported a total of $7.2 trillion in assets under administration. Of that total, $1.7 trillion consisted of
custody and safekeeping accounts, while total fiduciary accounts totaled $5.5 trillion.
6
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).
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companies in 1978 and continue to be today. 7 All of the Bank’s proposed activities are trust
company operations or activities related thereto and are permissible for a national bank under 12
USC 92a or 24(Seventh), as described below.
The Bank will act in a fiduciary capacity by offering custodial wallets as a service. The Bank
will only offer custody services for stablecoins. Trust company activities include providing such
custody services in a fiduciary manner. Therefore, the Bank’s proposed fiduciary custody
services are permissible under 12 USC 27(a) since they are trust company operations. 8
Additionally, the OCC has recognized that national banks may provide trading and exchange-
related services to their custody customers.9 These conversion services would be offered only to
custody customers and facilitate the use of custodied assets. The OCC recently approved several
national trust bank applications that proposed to engage in similar transactions and exchange
services for custody customers’ custodied assets. 10 Accordingly, the Bank’s conversion services
would facilitate and are connected to a customer’s use of the customer’s custodial account by
permitting customers to transfer and exchange custodied assets into and out of fiat currency and
USDC. Therefore, the Bank’s proposed conversion services are permissible as an activity of a
trust company or an activity related to the Bank’s proposed trust operations.
Moreover, the Bank’s proposed issuance of U.S. dollar-backed stablecoins is also permissible
under 12 USC 27(a) as operations of a trust company or activities related thereto. Various state-
chartered limited purpose trust companies, including BPTC, have been permitted to issue
stablecoins.11 Further, Congress in the Guiding and Establishing National Innovation for U.S.
7
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).
8
The OCC recently approved charters for national trust banks to engage in, among other things, digital asset custody
activities. See, e.g., OCC Corporate Decision No. 1367 (Feb. 20, 2026) (Foris DAX National Trust Bank); OCC
Corporate Decision No. 1365 (Feb. 12, 2026) (Bridge National Trust Bank); OCC Conditional Approval No. 1359
(Dec. 12, 2025) (Ripple National Trust Bank); OCC Conditional Approval No. 1356 (Dec. 12, 2025) (First National
Digital Currency Bank, National Association); OCC Conditional Approval No. 1353 (Dec. 12, 2025) (BitGo Bank &
Trust, National Association); and OCC Conditional Approval No. 1358 (Dec. 12, 2025) (Paxos Trust Company).
9
See, e.g., OCC Interpretive Letter No. 1188 at 4 (Dec. 9, 2025) (I.L. 1188) (“[t]he business of banking includes
brokerage of financial investment instruments” because “[a]s part of their traditional role as financial intermediaries,
banks have broad powers to buy and sell financial investment instruments as agent for customers” (quoting OCC
Interpretive Letter No. 499, Fed. Banking L. Rep. P 83,090, 1990 WL 538991, *2 (Feb. 12, 1990)). See also
I.L.1170; I.L.1184 (confirming that national bank may conduct fiat currency exchange and trade execution services
for custody clients).
10
See OCC Conditional Approval No. 1353 (Dec. 12, 2025) (BitGo Bank & Trust, National Association);
Conditional Approval No. 1358 (Dec. 12, 2025) (Paxos Trust Company, National Association); OCC Corporate
Decision No. 1355 (Dec. 12, 2025) (Fidelity Digital Assets, National Association); Corporate Decision No. 1365
(Feb. 12, 2026) (Bridge National Trust Bank), Corporate Decision No. 1367 (Feb. 20, 2026) (Foris DAX, National
Trust Bank); Corporate Decision No. 1370 (April 2, 2026) (Coinbase National Trust Company); and Corporate
Decision No. 1380 (July 2, 2026) (Connectia Trust, National Association).
11
See, e.g., Press Release: Superintendent Lacewell Announces Grant of DFS Trust Charter To Enable
GMO to Engage in New York’s Growing Virtual Currency Marketplace (Dec. 29, 2020) (authorizing GMO
to issue, administer, and redeem Japanese Yen and U.S. Dollar-pegged stablecoins in New York); Press
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Stablecoins Act (GENIUS Act) has expressly recognized uninsured national banks’ authority to
issue stablecoins.12
Finally, the Bank’s proposed issuer services for authorized stablecoin issuers are permissible
under 12 U.S.C. § 27(a) as an activity of a trust company or related thereto. The underlying
activities the Bank proposes to offer, including the technology to mint, burn and redeem
stablecoins, manage the stablecoin reserve, and implement compliance and risk management
controls, are activities permissible under 12 U.S.C. § 27(a) as an activity of a trust company or
related thereto, as described above. The Bank will provide third-party authorized stablecoin
issuers the same technology and operational capabilities that it uses for its own products and
services. The OCC has previously found that such digital asset creation, maintenance, and
verification activities are analogous to traditional trust operations, even though they incorporate
new technology and carry ancillary services with them.13 Similarly, the Bank will offer its
reserve management operations and risk and compliance services to authorized stablecoin
issuers. The third-party issuer will serve as the Bank’s customer and will determine which
services it requires from the Bank in connection with its own stablecoin program. The Bank’s
role is thus substantially the same whether it performs these functions for its own stablecoin and
custodial wallet products or provides them to an authorized third-party issuer. Moreover, the
OCC has previously recognized that provision of issuance-related services to enterprise
customers does not change their character and is permissible for national trust banks. 14
Accordingly, the Bank will be a national bank whose operations are limited to those of a trust
company or activities related thereto under 12 USC 27(a). 15
Public Comments
The OCC did not receive any comments related to this Application.
Release: Superintendent of Financial Services Linda A. Lacewell Announces Approval of First Gold
Backed Virtual Currency in New York State (Sept. 5, 2019) (authorizing Paxos Trust Company to offer
PAX Gold, a gold-backed virtual currency, as well as BUSD, a virtual currency pegged to the U.S. dollar).
12
See 12 USC 5901(11).
13
See OCC Conditional Approval No. 1366 at 3 (Feb. 13, 2026) (National Digital Trust Company).
14
See OCC Conditional Approval No. 1366 (Feb. 13, 2026) (National Digital Trust Company) (finding proposed
issuer services as a service provider permissible under 12 U.S.C. § 27(a) and stating that the OCC has long
recognized the power of national banks to act in ways that are premised on their traditional role in verifying the
identity of signing parties and the technology used by the bank to perform a service does not change the
permissibility. See also OCC Conditional Approval No. 1353 (BitGo Trust Company) (finding stablecoin issuance
services as permissible under 12 U.S.C. § 27(a)).
15
In 2003, the OCC amended 12 CFR 5.20(e)(1)(i) to address a subset of national banks, namely special purpose
banks that conduct at least one of the “core banking functions.” As evidenced by 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).
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Fiduciary Activities
The OCC approves your plan to continue 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
custody services in a fiduciary capacity. The Bank’s proposed fiduciary custody activity is
permitted under the bootstrap provision of 12 USC 92a and the New York state law, and its
provision of custody services will be subject to fiduciary duties and standards of behavior.
Conditions
This approval is subject to the following conditions and conversion requirements:
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, cease, or divest its proposed
stablecoin issuance and redemption activities and any other activities to comply 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 must: (i) give the Specialty Assets Supervisory Office at least sixty (60) days
prior written notice of its intent to significantly deviate or change from its business plan
or operations;16 and (ii) obtain the OCC’s written determination of no objection before
the Bank engages in any significant deviation or change from its business plan or
operations. For the avoidance of doubt, a significant deviation includes changes to the
Bank’s products and services as well as changes to its risk and operating limits, as
detailed in its business plan. The OCC may impose additional conditions it deems
appropriate in a written determination of no objection to the Bank’s notice. This condition
will remain in effect during the Bank’s first three years of operation.
4. The Bank must maintain a minimum of $6 million in tier 1 capital of which the greater of
at least 50 percent of its tier 1 capital or $3 million must be held in Eligible Liquid
Assets.17 The Bank must assess the appropriateness of its level of capital and liquidity on
16
If such deviation is the subject of an application filed with the OCC, no separate notice to the supervisory office is
required.
17
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
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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 operations as a national bank.
5. The Bank must maintain 180 days of operating expenses 18 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 operations as a national bank.
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 Bank shall 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 5.24(e) and does
not require the OCC to review or act on any such information within ninety (90) days.
This condition will remain in effect during the Bank’s first three years of operations upon
conversion to a national bank.
The conditions of this approval are conditions “imposed in writing by a federal banking agency
in connection with any action on any application, notice, or other request” within the meaning of
12 USC 1818. As such, the conditions are enforceable under 12 USC 1818. In addition, the
following conversion requirements must be met:
1. 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 Information).
2. 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 Conversion Completion Certificate. In addition, the board
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.
18
The minimum 180 days 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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of directors must review and adopt the policies and procedures at its first meeting. The
board of directors are responsible for regular review and modification of policies and
procedures and for assuring continuous compliance with them.
3. The Bank must apply for stock in a Federal Reserve Bank in accordance with 12 USC
222.19
4. The converting institution must ensure that all other required regulatory approvals have
been obtained.
5. The directors must own qualifying shares in conformance with 12 USC 72 and 12 CFR
7.2005.
Upon conversion to a national banking association, submit the enclosed Conversion Completion
Certificate certifying that you have done so. When the Bank has satisfactorily completed all of
the above steps and has satisfied any conditions imposed by the OCC, the OCC will issue a
Conversion Completion Acknowledgement officially authorizing the Bank to commence
business as a national trust bank. Shortly after conversion, you will receive a charter certificate.
If the conversion is not consummated within six months from the date of this decision, the
approval will automatically terminate unless the OCC grants an extension. The OCC does not
grant extensions of the approval period, except under extenuating circumstances, and expects the
conversion to occur as soon as possible after approval.
Waiver of Citizenship Requirement
The OCC also grants your request to waive the citizen requirement of 12 USC 72 for Directors
Nassim Eddequioiaq to serve as a member of the board of 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.
Conclusion
This conditional 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 laws and regulations. The
foregoing may not be waived or modified by any employee or agent of the OCC or the United
States.
19
See also 12 CFR 209.2.
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The OCC’s approval is based on BPTC’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.
Sincerely,
//signed//
Stephen A. Lybarger
Senior Deputy Comptroller
Chartering, Organization and Structure
Enclosures: Conversion Completion Certification