Ramp has joined the fintechs filing for a national trust charter. The OCC's part of that process now has dated precedents, and they are reasonably quick. The stages that come after it, a Federal Reserve account and a lawsuit filed on 2 October, have no published clock at all.
On 19 October Ramp, the corporate card and spend-management company, said it had applied to the Office of the Comptroller of the Currency to form Ramp National Trust Bank. The proposed bank would offer "fiduciary investment management and custody of digital assets" and would not take deposits or make commercial loans. Modern Treasury and Rain filed on 5 October. Block and Avant have applied within the past two months, according to Payments Dive.
Most coverage has asked whether these firms should be let in. For a founder weighing the same move, or a finance team told by a supplier that it is "becoming a bank", a more practical question is how long it takes. The dated cases point to four stages. Two belong to the OCC. Only the first behaves predictably.
Filing to conditional approval
Circle is the cleanest reference case, because both ends of its first stage are public. It applied on 30 June 2025 and was among five firms the OCC conditionally approved on 12 December 2025, with Ripple, BitGo, Fidelity Digital Assets and Paxos. That is 165 days. Three of the five were converting existing state trust companies, an easier road than a new build. Circle and Ripple were starting from nothing.
The rules promise nothing faster. Outside its expedited track, 12 CFR 5.20 sets no general deadline for an OCC charter decision. What has changed is appetite. Comptroller Jonathan Gould has said the agency doesn't "have a zero risk tolerance anymore", and in May that the statute "talks about a reasonable chance of success". By the count in the Independent Community Bankers of America's complaint, the OCC has approved or conditionally approved 21 national trust charters since January 2025, at least 13 of them for crypto firms. The approval rate has moved. The queue has not disappeared.
Conditional approval to opening
A conditional approval is a list of work. Capital has to be raised, management approved, a Bank Secrecy Act programme built and tested, systems examined. Under 12 CFR 5.20(i)(6)(iv), a preliminary approval expires if the bank has not commenced business within 18 months, unless the OCC extends it. That clock has bitten before. Protego, whose February 2026 conditional approval is now named in ICBA's suit, held a conditional approval in 2021 that lapsed after it failed to meet the pre-conversion requirements.
Circle received final approval on 10 July 2026, a little over a year after filing. The bank that emerged, First National Digital Currency Bank, operating as Circle National Trust, is narrower at launch than the one applied for. It starts with fiduciary custody for Circle and its affiliates, with a limited set of institutional clients to follow. Managing the USDC reserve, a central purpose of the original application, became a future capability, and USDC issuance is moving to a New York limited-purpose trust company instead.
That is the quieter lesson of stage two. A final approval can cover less than the application did, and the business case has to survive the difference.
The account that actually moves money
A trust charter does not come with access to Federal Reserve payment services. That needs a Reserve Bank account, decided by the Reserve Bank under guidelines the Fed finalised in August 2022. An uninsured national trust bank sits in the middle tier of those guidelines: federally supervised, not federally insured. The Congressional Research Service records that between December 2022 and May 2026 no Tier 2 applicant was approved for a master account. Three Tier 3 applicants were; about half of the others withdrew or were refused, and some requests have been pending for years. Kraken, a Wyoming special-purpose depository institution, was given a 12-month pilot limited account in March 2026.
The Fed's proposed answer is the payment account, published on 20 May 2026, with comments closing on 27 July. It would reach Fedwire Funds, FedNow, the National Settlement Service and free-of-payment Fedwire Securities, but pay no interest, offer no intraday credit, exclude FedACH and carry a closing balance limit of no more than $1 billion. Requests would generally be decided within 90 calendar days of complete documentation. Two caveats matter for anyone planning around it. The proposal is not final, and it does not widen legal eligibility. For full master accounts from Tier 2 and Tier 3 institutions, the Board declined to propose any timeline.
None of the October filers has said in its announcement that it wants a Fed account. Ramp, Modern Treasury and Rain all describe custody and fiduciary services. Payments Dive's reporting is that access to the Fed's accounts and payment rails is what the wider wave is about. If that is the prize, it sits in the one stage nobody has timed.
A clock set by a court
ICBA's suit, filed on 2 October in the US District Court for the District of Columbia, asks the court to vacate the OCC's March 2026 chartering rule, Interpretive Letter 1176 and Protego's conditional approval, and to bar the OCC from using the rule to grant further charters. It does not ask for existing charters to be unwound. If the court granted that last request, the firms exposed would be those still in stages one and two, which is where every October filer is. Until the court rules on it, every new filing carries that uncertainty.
Figure 1
Stage | What sets the clock | Dated reference | What it does not give you |
|---|---|---|---|
Filing to conditional approval | OCC review and public comment; no general deadline in 12 CFR 5.20 outside expedited review | Circle: 30 June to 12 December 2025, 165 days | Permission to operate |
Conditional approval to opening | Pre-opening conditions; approval expires after 18 months unless extended | Circle: final approval 10 July 2026; Protego's 2021 approval lapsed | Every activity in the application (Circle's reserve role deferred) |
Federal Reserve account | Reserve Bank discretion under the 2022 tiered guidelines; no timeline for Tier 2 or 3 master accounts | No Tier 2 master account approved, December 2022 to May 2026 (CRS) | A final payment-account rule, FedACH, interest or intraday credit, even if the proposal is adopted |
Litigation | ICBA v. OCC, D.D.C., filed 2 October 2026 | No ruling yet | Certainty for applications not yet approved |
Four clocks, two of them open-ended. Dates from the OCC's December 2025 approvals, Circle's July 2026 final approval as reported by The Block, 12 CFR 5.20, the Fed's payment account proposal (Federal Register, 26 May 2026), CRS Insight IN12722 (4 August 2026) and the ICBA complaint. The stage framing is FinancyHub's.
What the dates mean for builders and buyers
For a founder, the arithmetic is plain enough. A new trust charter is a project of a year or more before the bank does anything, with the 18-month expiry as a hard backstop, and the stage most likely to repay the effort is the one no regulator has timed. A plan that works only with a Fed account carries an open-ended dependency. A plan that earns its keep on custody and fiduciary business, with rail access as upside, is easier to defend to a board, to investors and to an examiner.
For the CFO office, a supplier's filing changes nothing about where your money or assets sit today, and the dates above suggest it will not for at least a year. Ramp sells to finance teams, and it is unlikely to be the last supplier in the finance stack to announce a filing. The useful response is to find out which stage an application has reached and which of the promised services depend on the stages after it.
Five questions for a supplier that says it is applying for a charter
Which legal entity holds our funds or assets today, and does that change if the charter is granted?
Which stage has the application reached: filed, conditionally approved, finally approved or open?
Which of the services you have described need a Federal Reserve account, and has one been requested?
What happens to those services if the conditional approval lapses or the OCC's chartering rule is set aside?
If our contract moves to the new bank, on what terms, and is our consent needed?
Circle's file is the best guide to the parts of the process that run on paper: about six months to a yes, about a year to a bank. The next filer can plan around those numbers. It cannot yet plan around the parts that run on the Fed's discretion and a court's timetable.
Sources and notes. Ramp's application as reported by Payments Dive and Banking Dive (20 October 2026) and FinTech Futures (20 October 2026); the Block and Avant applications and Payments Dive's reading of the motive are from the same Payments Dive report, which also carries Comptroller Gould's remarks. Modern Treasury press release, 5 October 2026; Rain's application as reported by Banking Dive, 6 October 2026. OCC conditional approvals of 12 December 2025 and the conversion and de novo split as reported by FinTech Weekly (6 March 2026), which also reports Protego's lapsed 2021 approval. Circle's application date, final approval and launch scope as reported by The Block (10 July 2026, updated 19 October 2026). 12 CFR 5.20(i)(6)(iv) and (j), eCFR. Federal Reserve Board, proposed payment account, Federal Register 2026-10375 (26 May 2026); summary of features per Mayer Brown (May 2026). Congressional Research Service, Insight IN12722 (4 August 2026), for master account outcomes by tier and Kraken's pilot account. ICBA v. OCC, No. 1:26-cv-03441 (D.D.C., filed 2 October 2026), as summarised by Ballard Spahr's Consumer Finance Monitor (5 October 2026). FinancyHub has no commercial relationship with any firm named. Journalism, not legal, compliance or procurement advice. Corrections welcome.
