Block Files OCC Charter for Builders Bank, a Purpose-Built Bitcoin Custody Trust
Block filed with the OCC to charter Builders Bank & Trust, N.A., a national trust bank that would custody bitcoin under direct federal oversight and replace the company's patchwork of more than 50 state money transmitter licenses.
Block wants a single federal charter to replace 50+ state licenses and compete directly with Fidelity Digital Assets and Coinbase Custody.
Key takeaways
- Block filed with the OCC on September 8 to charter Builders Bank & Trust, N.A., an uninsured national trust bank that would custody bitcoin and settle stablecoins, taking no deposits and making no loans.
- The charter, if approved, would consolidate the custody work Block currently runs under more than 50 state money transmitter licenses into a single federally supervised structure.
- Block is the latest entrant in a confirmed wave of firms building purpose-built federal custody infrastructure: Circle received final OCC approval in July 2026, and Ripple, Paxos, BitGo, and Fidelity Digital Assets have all received conditional approvals.
Block, Inc. filed an application with the Office of the Comptroller of the Currency on September 8 to charter Builders Bank & Trust, N.A., an uninsured national trust bank designed to custody bitcoin and digital assets under direct federal supervision, per the company's investor relations announcement. The bank would take no deposits and make no loans. It is a pure custody and fiduciary vehicle, nothing more.
Lee Woolley, Block's Digital Asset Strategy Lead, is named as proposed president and CEO of Builders Bank. His statement in the filing: "We look forward to working with the OCC as we pursue a charter designed to support the secure custody of assets for Block and its customers." Builders Bank cannot begin operations until the OCC grants the charter. Approval is not guaranteed.
What the Charter Actually Does
Block currently runs its bitcoin-related custody operations across more than 50 state money transmitter licenses. That patchwork means 50+ separate compliance regimes, 50+ renewal cycles, 50+ sets of state examiners. A single OCC national trust charter replaces all of it with one federal supervisor.
An uninsured national trust bank is not an alarming structure for this use case. FDIC deposit insurance was never relevant here because Builders Bank won't hold deposits. Custodied assets belong to the client, not to the bank. What the OCC charter does add is a federal capital requirement, governance standards, and examination authority. For institutional clients sitting on the sideline over "no regulated custodian" concerns, that matters.
Block already operates Square Financial Services, an industrial bank, since 2021. Builders Bank is a separate legal entity, purpose-built for custody. Bitkey, Block's self-custody hardware wallet, is unaffected by this filing.
The Institutional Bottleneck This Removes
The "no regulated custodian" objection has kept pension funds, endowments, and family offices either on the sideline or funneled through Fidelity Digital Assets and Coinbase Custody. The OCC has now conditionally approved Ripple, Circle, Paxos, BitGo, and Fidelity Digital Assets for national trust charters. Circle received final approval in July 2026, per Circle's own announcement. World Liberty Financial's trust company received conditional approval on August 14 after roughly 220 days of review. Kraken's parent company Payward has also applied.
Block doesn't arrive cold. It comes with existing custody operations under 50+ state licenses, a decade of customer data, and Cash App as one of the highest-volume consumer bitcoin on-ramps in the United States. A federal charter eliminates the per-state compliance drag and lets Block compete nationally for institutional mandates.
That competitive pressure lands directly on Block's existing treasury position and strategic posture. Fidelity Digital Assets and Coinbase Custody now face a competitor that already owns the consumer relationship at scale.
The stablecoin dimension is worth noting cleanly: Builders Bank is explicitly scoped for stablecoin custody as well as bitcoin. From a sound-money lens, those are distinct use cases. The bitcoin custody infrastructure is what moves the needle for the adoption argument.
The Thesis and Its Limits
Block filing this application is the clearest signal yet that bitcoin custody has crossed a threshold of regulatory seriousness that doesn't reverse. When a publicly traded company with a self-custody hardware wallet on one side files for a federally chartered custody bank on the other, the full-stack picture is explicit: hold your own keys with Bitkey, or let a federally supervised trust bank hold them through Builders Bank. The OCC pathway is confirmed and being used by multiple serious firms simultaneously.
The thesis fails if the OCC denies the charter outright, not with conditions but a flat denial, or if Block withdraws the application. An approval that bars Builders Bank from custodying bitcoin on behalf of external clients would also substantially weaken the institutional adoption argument. A multi-year review with no resolution softens it. Watch the OCC's 120-day review clock and any conditional approval language closely.
The SEC crypto custody rule moving through OMB review simultaneously creates a broader regulatory backdrop that shapes how much weight an OCC trust charter carries for institutional allocators. Both tracks matter.
What to Watch
The OCC has not confirmed receipt or set a public timeline. Based on recent precedent, World Liberty Financial's conditional approval took roughly 220 days. Circle's process moved faster and reached final approval. Block's review clock starts from the accepted application date. Any conditional approval language, particularly restrictions on custodying assets for external clients, would define how much competitive weight Builders Bank can actually carry.
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Frequently Asked Questions
An uninsured national trust bank holds assets in custody; it is not a deposit-taking institution, so FDIC deposit insurance never applied in the first place. Custodied assets are not bank assets. They belong to the client. The risk profile is structurally different from a depository bank failure. The OCC charter imposes capital requirements, governance standards, and examination authority, which provide a regulatory backstop without requiring deposit insurance.
The OCC targets a 120-day review but recent approvals have run longer. World Liberty Financial's conditional approval took roughly 220 days. Circle reached final approval. Block's timeline is unknown and approval is not guaranteed. Given the OCC's track record of conditional approvals for firms in this cohort, the more relevant question is what conditions, if any, get attached.
No. Builders Bank is a proposed separate legal entity from both Bitkey and Cash App. Bitkey remains a self-custody product. Cash App users are not the target customer of Builders Bank, which is designed as an institutional custody vehicle under federal supervision.
