OCC preliminary trust charter leaves World Liberty Financial aside
The OCC granted preliminary approval to World Liberty Trust Company, National Association. World Liberty Financial is a non-party, and the bank cannot open yet.
Having read Corporate Decision 1385, I treat the preliminary trust charter as an organising permit, with authority to open still ahead. On August 14, 2026 the Office of the Comptroller of the Currency (OCC) granted preliminary conditional approval for World Liberty Trust Company, National Association, in Bay Harbor Islands, Florida. World Liberty Financial LLC counts USD1 as a core product and shares indirect common owners with the proposed bank. Issuance would move from BitGo Bank & Trust, National Association, the exclusive issuer and custodian named in the decision, to an uninsured trust bank still short of the right to open.
Stephen A Lybarger, senior deputy comptroller for Chartering, Organization and Structure, signed the order. Final approval under 12 USC 27(a) arrives only after the preopening requirements are met, and until then the OCC can modify, suspend, or rescind the preliminary approval. Until opening, the name carries "In Organization".
The OCC hereby grants preliminary conditional approval of your charter application upon determining that your proposal meets certain regulatory and policy requirements.
What the trust charter covers
The bank would be wholly owned by WLTC Holdings LLC of Delaware. Accepted activities are trust-company operations: dollar-backed stablecoin issuance and redemption, nonfiduciary reserve maintenance, fiduciary digital-asset custody, and conversion of approved stablecoins already in custody into USD1 for institutional clients. The OCC approves buying USD1 reserve assets and liabilities from BitGo, exempt from Regulation W's quantitative limits and collateral requirements under 12 CFR 223.42(i). As of March 31, 2026, uninsured national trust banks reported $7.2 trillion in assets under administration.
Where a national trust charter stops
A national trust charter, a form Congress confirmed in 1978, covers trust-company work, while tokenised deposits and a full deposit franchise sit outside it. Condition 1 keeps the firm to its business plan and outside the Bank Holding Company Act definition of a bank. On the OCC's reading of the GENIUS Act, a payment stablecoin falls outside the deposit definition and outside FDIC insurance, and Community Reinvestment Act factors sit outside this approval with them.
The plan leaves WLFI tokens outside issuance, custody, and dealing. World Liberty Financial Inc is a non-party, and its investors stand apart from control of the bank. Stock in a Federal Reserve Bank under 12 USC 222 is on the chartering path, while a master account stays unrequested, with access left to the Federal Reserve.
Capital, control, and the opening clock
Seven comments came from four commenters, including concerns about conflicts involving President Donald J Trump and his family, Alexander Witkoff, Zachary Witkoff, and Emirati investors in World Liberty Financial Inc. The OCC cleared Zachary Witkoff as organizer, director, and president. Eric F Trump, Hamad Khlfan Ali Matar Alshamsi, and Zachary Folkman signed passivity commitments for DT Marks SC LLC, StringZ, and AMGUS, LLC that keep those holders off the board. The body dates the commitments July 13, 2026, the conclusion dates the exhibit June 13, 2026, and the signature lines are undated.
Tier 1 capital must be at least $20 million, with the greater of 50 percent of tier 1 or $10 million in eligible liquid assets, plus 180 days of wind-down expenses held separately as eligible liquid assets. Changes to products or risk limits need 60 days' notice and OCC non-objection for three years. Condition 2 requires the bank to conform, cease, or divest stablecoin activity if the GENIUS Act or later rules require it, in the OCC's sole discretion. Capital must be raised within 12 months and the bank must open within 18 months of August 14, 2026, or the preliminary approval expires, on the path in the Charters booklet.
The digital-assets licensing table shows Gurufin, Modern Treasury, and Rain national trust applications received from September 30 to October 5, 2026. This application is already Corporate Decision 1385 on the decisions docket, beside earlier approvals for Bridge, Foris DAX, BitGo, and Paxos. Zaria Systems is still waiting on an OCC charter.
World Liberty Financial opens for business only if capital, the preopening examination, and GENIUS Act conformity all clear, and the OCC then gives final approval under 12 USC 27(a). An unopened bank 18 months after August 14, 2026 loses the preliminary approval on the letter's own terms. Whether USD1 leaves BitGo depends on that opening, and large-bank access is a separate question in the OCC's debanking findings. The reserves move onto the bank's own books.
This article is informational analysis only and is not financial, investment, legal, or regulatory advice. Charter conditions change when the OCC modifies an approval, and the decision letter supersedes any summary. The Industry Spread has no affiliate or referral relationship with the firms named.
Reporting by Rick Steves. Filed 25 October 2026, 16:20 GMT.
Senior Reporter, Regulation and Fintech
Rick Steves has seen business and economics through many lenses. He joined the financial services industry in 2009, and has been a financial journalist since 2011.
