Introduction

The Office of the Comptroller of the Currency (the OCC) issued an interpretive letter on June 16, 2026 (Interpretive Letter No. 1192, and, here, the Interpretive Letter), that reinforces the primacy of the national bank charter over state licensing laws. The Interpretive Letter addressed the status of a digital assets national bank (the Bank) which converted from a New York State trust company license to an uninsured national trust bank charter in December 2025. The Bank provides cryptocurrency custody, trade execution services and other related services, including digital asset custodial accounts; transfer of assets services; custodial cash accounts; digital asset trade execution services; digital asset services…