The application
Dakota, a neobank that launched an enterprise stablecoin product in January 2026, has asked the Office of the Comptroller of the Currency for a de novo national trust bank charter. It currently works through money transmission licences and partner banks. If approved, Dakota National Trust Bank would offer fiduciary digital asset custody, issue dollar-denominated stablecoins and provide transaction settlement. A national trust bank is a limited-purpose federal charter, not a deposit-taking bank licence.[1]
It is not an isolated filing. Morgan Stanley and Coinbase hold conditional approval for comparable charters, Payward, which operates Kraken, is pending, and the regulator granted Circle a national trust bank charter in early August once it met the conditions of its initial approval. That is a queue, and a queue tells you the licence has become the standard route rather than an experiment.[1]
The balance sheets in between
Ryan Bozarth, who runs Dakota, describes the point of the charter as fewer intermediaries meaning more control, more reliability and a cleaner experience for the people the company serves. As an operating claim about cost and speed that is straightforward. As a risk claim it needs one more step, because each intermediary in the current arrangement is also a balance sheet, and a balance sheet is what absorbs a mismatch between the moment a holder asks for dollars and the moment the reserve assets can be turned into dollars. Removing partner banks does not remove that mismatch. It concentrates it in the chartered entity.[1]
Jasper Sneff Nanni of FS Vector supplies the timing detail that makes this worth watching now rather than later: national trust banks do not need to wait for final GENIUS Act rules to issue, redeem and hold custody of stablecoins. So issuance under the charter can begin before the rulebook that governs reserve composition and liquidity is finished. The resilience case against alarm is genuine and should be stated plainly. A limited-purpose charter is a narrower activity than deposit banking, custody obligations are supervised, and a supervisor that has already imposed conditions on Morgan Stanley, Coinbase and Circle is not absent from the process.[1]
Who takes the redemption
Which leaves one bounded question, and it is a question about people rather than about a chart. In today's arrangement, an enterprise client asking for dollars reaches a partner bank that holds a settlement account and can wait a day. Under the charter, the same request reaches an institution whose entire business is custody, issuance and settlement, and whose ability to pay depends on how quickly its reserve assets convert. The holders exposed to that difference are enterprise treasurers who treat the token as a cash equivalent, and they will find out what it is on the first day when everyone asks at once rather than on the day the charter is granted.[1]