Three Trust Charters, $26 Million in Capital Floors, and the Part the OCC Didn't Approve

The Office of the Comptroller of the Currency moved three stablecoin firms closer to federal trust-bank status on Sept. 18. Agora, Catena and Bastion all got the nod. None of them can open yet.

Here's the split. Agora and Catena received preliminary conditional approval to organize brand-new national trust banks. Bastion took a different road. It already runs under a New York trust charter, and the OCC conditionally approved its conversion into Bastion Platforms National Trust Company. That difference matters. Agora and Catena still need final approval before they take a single customer. Bastion just needs to finish the conversion.

The clocks are tight. Agora and Catena have to raise capital within 12 months and open within 18. They also must notify OCC chartering staff at least 60 days before a scheduled opening. Bastion's approval terminates automatically if the conversion isn't completed in six months. No firm opening dates for any of the three.

Capital floors anchor the whole framework. Agora and Catena each need $10 million in tier 1 capital, with the greater of 50% or $5 million held in eligible liquid assets. Bastion's floor is $6 million tier 1, plus the greater of 50% or $3 million liquid. All three must separately hold liquid assets equal to 180 days of operating expenses for a distressed wind-down during their first three years under the federal charter. And none of them will be FDIC insured. Stablecoins aren't deposits, and the OCC says so plainly in Catena's decision.

That's the point. This isn't a rescue of anything. It's plumbing.

Scale backs up the pattern. Comptroller Jonathan Gould said 23 of 40 new-charter applications filed over roughly 18 months involved digital assets. The GENIUS Act implementing rules were still proposed as of Sept. 22. And the Conference of State Bank Supervisors keeps arguing that the OCC's trust-charter reach exceeds the National Bank Act. A repeatable administrative process isn't the same thing as settled law.

Enterprise blockchain is boring. That's why it works. A federal trust charter buys national reach and one supervisor instead of fifty. It doesn't buy customers, reserve partners, enterprise integrations or a launch that actually functions. Agora plans to shift AUSD issuance out of Bermuda only after the bank is established. Catena is selling custody and execution to the companies deploying AI agents. Bastion is chasing white-label issuance and custodial wallets for enterprises. Three businesses, one perimeter.

Watch the 12-month capital raises. That's where the real sorting happens, not in the approval letters.