Zerohash, the crypto infrastructure firm, has filed a second application for an OCC trust bank charter after its initial filing was returned as materially deficient in July, according to company statements. The second filing narrows the scope to national trust activities, a departure from the first effort which sought approval for digital asset custody, custodial staking, transfer agent functions, and stablecoin management.
The OCC's process distinguishes between rejection and return for material deficiency. When an application is returned deficient, the applicant may resubmit. Zerohash's first filing, submitted in March, was returned on July 17 after the regulator determined it lacked sufficient detail or supporting documentation to proceed. The company filed a second application within weeks with reduced scope.
Zerohash provides custody, settlement, and financing infrastructure for institutions trading digital assets. The firm counts Morgan Stanley as a client and has positioned itself as a neutral settlement layer for crypto trading. A trust bank charter would allow it to hold client assets directly and offer federally insured deposit-like services, a privilege currently restricted to institutions with explicit OCC approval for digital asset activities.
The OCC began accepting digital asset trust bank applications in January 2024, creating a pathway for crypto-focused firms to operate as federally chartered institutions without going through state banking regulators. Zerohash's first bid placed it among a small cohort of digital asset platforms pursuing this route. The OCC flagged concerns about the breadth of activities or the depth of the compliance framework in the initial submission, and the company narrowed its second application accordingly.
Few firms have successfully obtained OCC trust bank charters for digital assets. The regulator has approved limited charters and returned multiple applications for deficiency or additional information, making the approval bar clear and high. Zerohash's pivot to a narrower scope follows this pattern when applicants address specific gaps the OCC cited.
The company is working against a regulatory environment where digital asset banking remains contentious on Capitol Hill. Some lawmakers have sought to restrict or block OCC trust bank chartering for crypto firms, though existing law permits the agency to grant them. The second filing also arrives as institutional crypto adoption accelerates, with major financial firms increasing their infrastructure spend on custody and settlement.
Zerohash moved from filing in March to receiving a deficiency notice by mid-July, a timeline consistent with OCC review speed. The company filed a narrower charter request following the deficiency determination. If the second filing clears the initial review stage, Zerohash would face further OCC examination before approval.
