Galaxy trust bank application awaits OCC decision

Galaxy Digital says its subsidiary has applied to establish Galaxy National Bank, a proposed US national trust bank based in New York. The October 29 announcement concerns an application to the Office of the Comptroller of the Currency (OCC). It does not announce approval or the start of operations under a federal charter.

If approved, the proposed institution would provide digital-asset custody, trading and staking services, together with fiduciary investment advisory services. Galaxy says the applicant is Galaxy Digital LP. The proposal would place those services within an OCC-supervised trust institution, but the company explicitly makes that outcome dependent on the regulator’s decision.

Galaxy’s announcement identifies risks including refusal, approval on different terms, additional conditions and a longer review than anticipated. It also lists the ability to meet capital, liquidity, governance and compliance requirements among the uncertainties. These qualifications separate the company’s intended business model from an actual regulatory approval.

The OCC maintains a public page for pending digital-asset licensing applications and directs readers to its Corporate Applications Search for further details. The table reviewed for this report did not list Galaxy. That absence does not disprove the company’s announcement, but this report does not treat the table as independent confirmation of receipt or assign an OCC filing date.

Application, preliminary approval and opening are separate

The OCC’s existing Charters licensing manual describes a two-stage approval process. Preliminary approval allows organisers to proceed with setting up the institution after the first phase of review. Final approval means the charter has been issued and the institution can begin banking business. Merely announcing an application does not establish either stage.

Between preliminary approval and opening, organisers arrange the practical work needed to operate. The manual describes hiring staff, raising capital, preparing premises and developing operating policies. It also explains that other necessary approvals must be obtained before opening, including deposit insurance where applicable. Those are general procedural distinctions, not reported milestones for Galaxy.

For a trust-bank application, the OCC reviews fiduciary powers within its charter review rather than requiring a separate application for those powers. Organisers must still supply the relevant information. The manual also calls for a detailed analysis supporting proposed capital and liquidity levels, with the regulator assessing the business before setting minimum requirements.

The existing trust-bank framework

A separate OCC rule, effective April 1, 2026, clarified its approach to national banks limited to trust-company operations and related activities. The regulator said such institutions may conduct non-fiduciary activities alongside fiduciary activities. This is existing regulatory background to the charter category, not a fresh rule issued with Galaxy’s October announcement.

The February 27 bulletin explains that the amendment replaced references to fiduciary activities with trust-company operations and related activities in the chartering regulation. The OCC described the change as neither expanding nor contracting its chartering authority. It applies to applicants for this limited-purpose category, rather than granting an automatic permission to any particular applicant.

Capital and liquidity remain ongoing responsibilities

The OCC’s longstanding capital and liquidity guidance explains why supervision would extend beyond an opening decision. It assigns responsibility to directors and management for maintaining adequate resources and planning processes. The guidance notes that most national trust banks do not accept deposits, make loans or carry Federal Deposit Insurance Corporation insurance. Capital and liquidity must be evaluated separately, and assets already pledged or committed to minimum capital requirements are not available as primary liquidity.

The guidance expects trust banks to review liquidity at least quarterly and capital at least annually. More frequent analysis can be appropriate when a business grows rapidly, enters new activities or has not achieved stable profitability. These are general supervisory expectations, not evidence that the OCC has set Galaxy’s eventual financial conditions.

Contingency funding plans are also part of the existing framework. The guidance discusses adverse scenarios such as falling revenue, loss of an important account relationship or departure of a key trust officer. For readers following the application, the distinction is between a proposed federal structure and the ongoing responsibilities a supervised institution would have to meet.