Bastion Platforms seeks to convert its state trust charter

• Key insight: A white-label stablecoin issuer applied to convert its trust charter from New York State to a national OCC-granted charter.
• What's at stake: Bastion is the latest among several digital asset firms to pursue a trust charter conversion in recent months.
• Expert quote: "A national trust bank charter takes a lot of the regulatory complexity out of a nationwide white-label stablecoin offering, which means removing uncertainty for customers." — Jasper Sneff Nanni, managing principal for FS Vector

Bastion Platforms, a stablecoin infrastructure technology provider, is applying to convert its New York State trust bank charter to a national trust charter.

The fintech, a Campbell, California-based company that sells stablecoin technology to enterprise clients, submitted its national trust bank application to the Office of the Comptroller of the Currency under the name Bastion Platforms National Trust Company. The agency marked Bastion's application as a "conversion."

Charter conversions from state to federal, or vice versa, have been used by domestic banks, international banks and credit unions to shift their regulatory strategy as institutional goals change. Additionally, three of the five national trust charter approvals given to digital asset firms by the OCC last December were conversions from state to national charters.

A public version of the application was not released by the OCC. According to its digital asset licensing applications page, "applications to convert to a national bank are not included [published] as these applications are not subject to public comment."

The agency did not respond to a request for comment by time of publication.

Bastion secured a limited purpose trust company charter from the New York State Department of Financial Services, or NYDFS, in February 2025 upon acquiring Dibbs Trust Company. The firm secured the state-level charter in order to launch a white-label stablecoin issuance platform, according to a company statement at the time.

Emily Goodman, partner at financial services advisory firm FS Vector, told American Banker that the New York State trust charter Bastion holds doesn't provide an exemption from state licensing requirements.

"Depending on the activities conducted, a charter holder may still need to obtain and maintain state-level licenses (such as money transmitter licenses) across multiple jurisdictions," she said. "Maintaining a state trust charter alongside state licenses introduces meaningful operational complexity and cost."

However, Goodman said that the New York State trust charter still remains a credible and well-regarded framework for trust operations, "particularly for companies that value close engagement with a leading state regulator."

Michele Alt, co-founder and partner at financial services advisory firm Klaros Group, told American Banker that converting from a state trust charter to a national one can alleviate some of the challenges associated with state-level regulations.

"National banks, including national trust banks, enjoy federal preemption of state laws that 'conflict or significantly interfere with' the exercise of their federal banking powers," she said. "This, along with the OCC's receptivity to innovative business models, contributes to interest in de novo and conversion applications."

A national trust charter can also make a difference in regulatory posture. An OCC-granted charter, according to Goodman, could signal additional value to a firm's partners and customers.

Jasper Sneff Nanni, managing principal for FS Vector, also said that having a national trust charter would ensure that product availability for digital asset companies like Bastion wouldn't vary from state to state.

"A national trust bank charter takes a lot of the regulatory complexity out of a nationwide white-label stablecoin offering, which means removing uncertainty for customers," Nanni told American Banker.