Zerohash refiles its trust bank charter application to OCC

• Key insight: Zerohash is attempting for the second time to get a national trust bank charter from federal regulators.
• Expert quote: ""These are the kinds of changes you'd expect from an applicant that went through the OCC's additional information request and field investigation process and recalibrated. —FS Vector's Evey Guo
• Forward look: The company anticipates filling two C-suite roles for the proposed trust bank prior to beginning operations.

Digital asset infrastructure provider Zerohash is trying, again, to acquire a national trust bank charter from the Office of the Comptroller of the Currency.

The refiled application, submitted to the agency on August 18, is Zerohash's second attempt to get a trust charter after its initial application was returned without a decision or public announcement by the OCC back in July. Zerohash told American Banker at the time that the company planned to refile its application by the end of August.

The refiling comes as the OCC has approved multiple charter requests for de novo banks and trust companies so far this year, most recently World Liberty Trust Company, while also issuing public denials to two firms (Bunq and Wise). 

Zerohash, whose clients include Morgan Stanley, One Pay and Stripe, originally filed for a national trust bank charter from the OCC in March of this year. A comparison of the two filings shows a narrower scope for proposed offerings and changes to the leadership section for the proposed Zerohash National Trust Bank.

"These are the kinds of changes you'd expect from an applicant that went through the OCC's additional information request and field investigation process and recalibrated," FS Vector principal Evey Guo told American Banker.

The August application said that the proposed trust bank would offer "custody over digital assets and traditional assets (e.g., fiat currency); certain digital asset trade services; custodial staking and validation activities; and fiduciary settlement, clearing and escrow services."

In the original March application, however, the proposed trust bank was originally planning to offer "custody over digital assets, fiat currency, and other assets; custodial staking and validation activities; transfer agent services; trade execution; stablecoin management; and settlement, clearing and escrow services."

The refiled application removed stablecoin management and transfer agent services from its proposed offerings, even as it currently provides stablecoin infrastructure for institutional clients.

"Given Zerohash already conducts both through its North Carolina state trust company, this looks like a licensing structure decision –- keep the national trust bank focused on custody and ancillary activities, and keep stablecoin and transfer agent operations under existing state authority for the de novo period," Guo said.

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The other main change in the refiled application concerns the publicly available leadership section. The August filing said that the company anticipates filling two roles — president/chief operating officer and chief trust officer — for the proposed trust bank prior to beginning operations. Both roles have active hiring pages on Zerohash's careers page, alongside open roles for a chief compliance officer and global chief compliance officer for the parent company. 

A Zerohash company representative previously confirmed with American Banker that Stephen Gardner, the proposed CEO for Zerohash National Trust Bank, was the current chief compliance officer and chief legal officer for Zerohash. Gardner's LinkedIn says that he assumed the title of co-president as of July of this year, but the company's media page still lists him under the chief compliance and legal officer titles. 

Zerohash did not respond to requests for comment from American Banker by time of publication.

In the first application filed this spring, the role of chief trust officer was originally allocated to Andrew Lucas, Zerohash's senior vice president of global regulation. Lucas is no longer listed among the leadership for the proposed trust bank, but is still a co-signer on the August refiling and listed as the primary contact person at the company for the application. Lucas did not immediately respond to a request for comment from American Banker.

"The OCC's review may have surfaced questions about whether the original team was sufficient  to support everything in the first application," Guo said.