Zerohash to Refile U.S. Trust Bank Bid After OCC Returns Application

What to Know

• Zerohash, a crypto infrastructure provider used by major financial firms, did not receive approval in its first attempt to become a U.S. national trust bank.
• The U.S. Office of the Comptroller of the Currency returned the application rather than formally denying it.
• Under OCC policy, a returned filing can indicate that an application was considered materially deficient.
• Zerohash said the return was an administrative process coordinated with the OCC and was not a substantive decision on the merits.
• The company said current operations continue under existing regulatory approvals.
• Zerohash plans to refile by the end of the month with a narrower scope focused on national trust activities aligned with its rollout timeline.
• The initial application was filed in March and returned on July 17, according to OCC records.
• The company has provided crypto infrastructure for firms including Morgan Stanley’s E*Trade, BlackRock, Franklin Templeton, Stripe, Interactive Brokers and DraftKings.
• Zerohash is already a state-chartered trust bank, and its E*Trade business does not depend on receiving a federal charter, a person familiar with its operations said.
• The setback comes as the OCC has conditionally approved or received applications from a growing group of crypto and fintech firms seeking national trust bank status.

Zerohash Faces a Delay in National Trust Bank Push

Zerohash is preparing a revised application for a U.S. national trust bank charter after the Office of the Comptroller of the Currency returned its initial filing, placing the crypto infrastructure company outside the latest wave of digital asset firms seeking federal trust bank status. The company, which handles backend crypto operations for prominent financial platforms, said it expects to refile this month and is aiming for a faster review under a more focused proposal.

The OCC’s action was not framed as a formal denial. Instead, the agency returned the application, a procedural outcome that, under OCC policy, may occur when a filing is considered materially deficient. That distinction matters because a denial typically comes with a more direct regulatory judgment on the application, while a return ends the process without a final decision on the merits. Zerohash said the process gives it room to submit a revised filing and emphasized that its existing business is not disrupted.

In a statement, Zerohash said the return of the application was an administrative process that allows it to refile this month. The company said the approach was taken in coordination with the OCC, was not a substantive decision on the merits of the application and does not affect current operations, which continue under existing regulatory approvals.

A Narrower Application Is Expected

Zerohash indicated that its first application may have sought approval for a broader set of activities than the company now intends to pursue at the start. The initial filing covered a wide range of digital asset and fiduciary services, according to the company. Its next effort is expected to take a more sequenced approach, beginning with a more focused request for approval of national trust activities aligned with its intended rollout timeline.

That narrower strategy may reflect a broader reality for crypto firms seeking federal banking credentials. Trust bank charters can offer a clearer regulatory footing for custody, fiduciary and related activities, but the OCC still expects applicants to meet statutory and regulatory standards. For digital asset companies, those reviews may involve detailed scrutiny of governance, compliance, risk management, financial condition, leadership and operational controls.

Zerohash said it looks forward to swift review of the resubmission. The company has not disclosed the specific changes it will make, and OCC records do not reveal why the initial application was returned. Because returned filings do not carry the same detailed explanation as formal denials, the exact regulatory concerns remain unclear.

OCC Records Show the Filing Was Returned on July 17

The application was originally submitted in March and was returned on July 17, according to OCC records. The timing placed Zerohash among a cluster of digital asset and fintech firms pursuing national trust bank status as federal regulators and lawmakers sharpen their approach to crypto banking, stablecoins and digital asset custody.

The company had publicly signaled its federal charter ambitions. Zerohash had advertised roles tied to a planned national trust bank, including positions for a national trust officer and a chief operating officer at a Zerohash National Trust Bank with a pending charter application. Zerohash Co-president Stephen Gardner’s professional profile also listed him as CEO of the pending Zerohash national trust bank.

The returned filing leaves Zerohash in a different position from some other applicants. In other recent cases, fintech firms Wise and Bunq received denials. A return, by contrast, is an administrative end to the filing process and does not necessarily close the door to a future application. Zerohash has signaled that it intends to move quickly to restart the process.

Regulatory Momentum Around Digital Asset Trust Banks

The OCC has been a focal point for crypto companies seeking national trust bank charters. Under U.S. Comptroller of the Currency Jonathan Gould, the agency has welcomed a number of digital-native banking initiatives, with several firms pursuing or receiving provisional approvals for trust bank structures tied to digital assets.

The broader rush has been amplified by the Guiding and Establishing National Innovation for U.S. Stablecoins Act, which formally established a legal structure for U.S. stablecoin issuers. As stablecoin and custody rules become more defined, crypto infrastructure companies have had stronger incentives to seek federal banking credentials that could help support institutional adoption and national-scale operations.

The Independent Community Bankers of America objected to Zerohash’s application in April. In its letter, the group noted that in less than twelve months the OCC had conditionally approved or received applications from Circle Internet Group, Ripple, Paxos Trust, BitGo, Fidelity Digital Assets, Crypto.com, Payoneer and Zerohash. The group also said the pace, described as eleven filings or approvals in under one hundred days in some windows, risked moving faster than deliberate, transparent policymaking.

Community bank objections highlight a key tension in the charter debate. Digital asset firms argue that clearer federal oversight can improve safety, compliance and market structure. Some traditional banking groups counter that rapid charter expansion could create policy gaps or allow new entrants into banking-like activities before regulators and the public have fully evaluated the risks.

Zerohash’s Role in Crypto Market Infrastructure

Zerohash is best known as a crypto infrastructure provider rather than a consumer-facing token platform. Its technology powers digital asset services for major firms that want to offer crypto access without building every piece of trading, settlement, custody support and compliance infrastructure themselves. The company has handled crypto plumbing for Morgan Stanley’s E*Trade and has also powered infrastructure for BlackRock, Franklin Templeton, Stripe, Interactive Brokers and DraftKings.

That position makes the charter effort significant for the broader institutional crypto ecosystem. Infrastructure providers sit behind many branded crypto offerings and can influence how traditional financial companies enter the market. A national trust bank charter could potentially support expansion of fiduciary services, custody-related activities and institutional relationships, though Zerohash has stressed that its existing operations are already supported by current regulatory approvals.

A person familiar with the company’s operations said Zerohash’s business with E*Trade does not depend on obtaining a federal charter. That point is important for clients and counterparties watching the OCC process, because it suggests the returned filing does not automatically interrupt current service relationships.

Investment Talks and Corporate Activity Add Context

Zerohash has also been pursuing additional investment, with market discussions in May pointing to a potential valuation above $1.5 billion while its federal trust bank application was still active. The company had also been in acquisition talks with Mastercard in recent months, but those talks fell through.

The valuation discussions and acquisition interest underline the strategic importance of crypto infrastructure as large financial companies continue exploring digital asset products. Even in a market where token prices can be volatile, firms that provide regulated access, custody support, settlement tools and compliance infrastructure can attract interest from payment networks, brokerages, asset managers and banks.

The returned OCC application may complicate the narrative around Zerohash’s federal expansion plans, but it does not end them. The company’s stated plan is to refile with a narrower application and seek swift review. Market participants will be watching whether a more limited scope is enough to address the issues that led the OCC to return the initial filing.

Compliance Lawsuit Remains an Overhang

Zerohash has also been involved in a legal dispute with former chief compliance officer Edgar Guerra, who claimed in a California lawsuit that he was fired in an effort to mask compliance issues he had identified. Guerra, a former Federal Reserve regulator, alleged that he and his staff internally identified more than 200 significant compliance gaps, including issues related to the company’s money-laundering controls. He also claimed that some shortcomings had previously been noted and insufficiently remedied.

It is unclear whether OCC officials were aware of or concerned by the allegations, or whether the lawsuit played any role in the returned application. Zerohash declined to comment on the case. The company’s efforts to push the dispute into arbitration were preliminarily rejected.

In 2022, when Guerra was six months into the role from which he would later be fired, he said in an interview that the company was trying to comply with a couple of dozen compliance professionals at a firm of about 150 employees at the time. He also said he had been brought on by leadership that was committed to making compliance a competitive advantage.

What Comes Next for the Charter Bid

The immediate question is whether Zerohash’s revised application will satisfy the OCC’s expectations. The regulator recently explained that it may return a filing if it lacks necessary information about a company’s finances or officers. The OCC also said a filing may be returned as materially deficient if, after the agency asks for additional information needed to assess statutory or regulatory criteria, the responses do not sufficiently address the requests.

Because the agency has not disclosed the specific reason for returning Zerohash’s application, outside observers cannot determine whether the issue involved documentation, scope, governance, risk controls or another part of the filing. Zerohash’s decision to narrow the requested approval suggests the company believes a more staged application could be easier for regulators to assess.

For the crypto industry, the case is a reminder that a friendlier policy environment does not mean every charter application will move smoothly. Federal trust bank status remains a high bar, particularly for firms operating in digital assets, where regulators often focus on custody controls, anti-money-laundering systems, cybersecurity, operational resilience and management oversight. Zerohash’s next filing will test whether a more targeted proposal can move through the OCC process more quickly.

Frequently Asked Questions (FAQs)

What happened to Zerohash’s OCC application?

The OCC returned Zerohash’s application for a U.S. national trust bank charter. The application was not formally denied, but the process for that filing ended, and Zerohash now plans to submit a revised application.

Does a returned application mean the same thing as a denial?

No. A returned application is different from a formal denial. Under OCC policy, a return can indicate that a filing was materially deficient, but it does not represent the same type of final decision on the merits as a denial.

When did Zerohash file and when was the application returned?

Zerohash submitted the original application in March, and OCC records show that the filing was returned on July 17.

Why does Zerohash want a national trust bank charter?

A national trust bank charter could support federally supervised trust activities tied to digital assets, including fiduciary and infrastructure services. Zerohash has said its next application will seek a more focused approval aligned with its rollout timeline.

Will Zerohash’s current operations be affected?

Zerohash said the returned application does not affect its current operations, which continue under existing regulatory approvals. A person familiar with the company’s operations also said its E*Trade business does not depend on receiving a federal charter.

Which companies use Zerohash’s crypto infrastructure?

Zerohash has provided crypto infrastructure for major firms including Morgan Stanley’s E*Trade, BlackRock, Franklin Templeton, Stripe, Interactive Brokers and DraftKings.

What did the OCC say about returned filings?

The OCC has said it may return a filing if it does not include necessary information about matters such as company finances or officers, or if responses to additional information requests do not sufficiently address what the agency needs to assess statutory or regulatory criteria.

Is Zerohash already regulated in any way?

Yes. Zerohash is already a state-chartered trust bank, and the company says its current operations continue under existing regulatory approvals.

What is the next step for Zerohash?

Zerohash plans to refile by the end of the month with a narrower application focused on national trust activities. The company said it is looking forward to swift review of the resubmission.

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