Ramp Seeks OCC Trust Bank Charter for Digital-Asset Custody as Legal Limits Face Challenge

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Ramp is seeking a federal trust bank charter to offer digital-asset custody and fiduciary investment management. The proposed bank would be narrower in scope than a conventional lender. What it could do would depend on the charter the OCC grants.

The New York-based spend-management fintech says it has applied to the Office of the Comptroller of the Currency (OCC) to establish Ramp National Trust Bank. Ramp says a charter would place the proposed entity “under a consistent federal regulatory framework.”

A national trust bank charter is different from a full-service bank charter. Trust institutions may manage assets on a client’s behalf and provide custody, or safekeeping, for assets. The activities they can carry out depend on the specific charter and regulatory approvals. A trust charter does not automatically authorize every service associated with a bank.

Ramp says its proposed entity “will not take deposits or make commercial loans.” That describes the company’s plan, not a final regulatory decision. The OCC has not disclosed a review timeline or the specific requirements Ramp would need to meet. Ramp’s application for a national trust bank charter remains under OCC review.

A contested route into financial services

The OCC’s use of limited trust charters for crypto firms has drawn opposition from the Independent Community Bankers of America (ICBA), which has sued the agency. The trade group argues that Congress did not create the charter as “a side door into the banking system for crypto firms, ” said ICBA chief executive Rebeca Romero Rainey.

The dispute is about how far these charters can reach and how the OCC should use its authority. A trust charter can provide a federal framework for approved activities, but it does not let a company bypass regulatory scrutiny. Bastion’s conditional OCC approval and Circle’s conditional OCC approval show the charter path now under scrutiny. The ICBA’s challenge, and what it could mean for future applicants, remain unresolved.

Ramp’s application would do more than add a custody provider. It puts the company’s proposed services before a federal regulator while the limits of the trust-charter path are being contested. Even if approved, the charter would not prove that every digital-asset custody model is safe or suitable. Custody still carries operational and compliance risks.

Key questions

  • What is Ramp seeking?

    A national trust bank charter for a proposed entity focused on fiduciary investment management and digital-asset custody.

  • Would the proposed entity take deposits or make commercial loans?

    Ramp says it would do neither. The activities it may carry out would depend on the charter and OCC approval.

  • Is a trust bank the same as a full-service bank?

    No. A trust bank’s authorized activities are limited by its charter and applicable regulation. It is not automatically permitted to take deposits or make commercial loans.

  • When will the OCC decide?

    The OCC has not disclosed a review timeline.

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