Modern Treasury provides software and payment infrastructure for fiat and stablecoin transactions.
On October 5, 2026, the company announced an application to establish a separate limited-purpose national trust bank. The application is not approval to operate a bank.
Modern Treasury says it submitted an OCC application for a limited-purpose trust bank. The proposed bank would provide digital-asset custody and related fiat services, but would not make loans or issue stablecoins.
Bank & fintech · Charter application
Related permanent research
Payments & financial infrastructureResearch updated Oct 5, 2026
Sponsor banking combines distinct funding, issuing and servicing roles. Cross River’s GoodLeap facility illustrates those boundaries, while Modern Treasury’s proposed custody bank shows why a charter application is not production lending or measured adoption.
Policy & official records
Curated library records that name Modern Treasury or connect through its linked research. The official source provides full scope and status.
OCC / FDIC / Federal Reserve2024-07-25 · Supervisory statement
Overview of payment systems, payment types, operational exposures and risk-management practices. Useful context for bank payment operations and outsourced processing.
Procedures for evaluating technology and service-provider controls as part of consumer-compliance management. Connects system design, oversight and testing to risks of consumer harm.
Guidance on fraud governance, prevention, detection, response and loss monitoring across the bank. The posted bulletin marks removal of reputation-risk references on March 20, 2025.
Examination reference for board oversight, management responsibilities and bank risk governance. Use the posted revision notices and applicable rules alongside this July 2019 handbook.
Consumer-compliance risk management within the OCC’s risk-based examination approach. Useful for evaluating compliance programs and oversight across products and service providers.
Covers management oversight, the compliance program, service-provider controls, violations and consumer harm. Useful for testing whether responsibilities and corrective actions work across the product lifecycle.
FDIC compliance and Community Reinvestment Act examination resource. Individual chapters have different revision dates; newer laws, final rules and agency instructions must be read alongside older examination text.
Restrictions and exceptions governing activities and investments of insured state banks and savings associations, including subsidiaries and FDIC consent. Useful when assessing charter-specific partnership or product authority.
Subpart C contains the FDIC-supervised bank and service-provider notification framework. Section 304.23 sets the bank’s outside limit at 36 hours after determining that a notification incident occurred; service providers have a distinct trigger under §304.24.