World Liberty Trust Company’s charter took 220 days from filing to conditional approval, roughly 120 days past the target the OCC has set for deciding every application. The Office of the Comptroller of the Currency has said it aims to decide every charter application within 120 days.
The Trump family’s proposed national trust bank waited longer for its charter decision than any other recent fintech or digital-asset applicant, according to Office of the Comptroller of the Currency data analyzed by Bloomberg.
The Numbers
World Liberty Financial’s subsidiary WLTC Holdings filed its application on January 5, as The Crypto Times reported at the time. The OCC granted preliminary conditional approval on August 14 in Corporate Decision #1385, a span of roughly 220 days.
Bloomberg’s comparison of recent fintech and digital-asset charter approvals places the median during the current administration at 126 days. Fidelity Digital Assets cleared in 71 days, Upstart in 98, Bridge in 120, Nubank in 121, Erebor in 125, Mercury in 127, and Coinbase in 181. The median during the previous administration was 176 days.
World Liberty’s 220 sits above all of them.
Comptroller Jonathan Gould has set a target of deciding every charter application within 120 days. The agency said this month that it has received 40 de novo applications over the past 18 months and has reached decisions on some of them within 120 days of receiving a complete application.
What the Letter Shows About the Delay
Corporate Decision #1385 records that the OCC received seven comments from four commenters and devotes several pages to responding to them.
Four commenters raised conflicts of interest involving the bank, President Donald Trump and his family, Alexander and Zachary Witkoff, and Emirati investors in World Liberty Financial. Three argued the bank could receive preferential treatment because the Comptroller is a presidential appointee. Others raised CFIUS review, Community Reinvestment Act applicability, Bank Holding Company Act status, deposit insurance, and the Emoluments Clause.
The letter also records that three investors—StringZ Holdings RSC (DE) LLC, DT Marks SC LLC, and AMGUS, LLC—signed passivity commitments limiting their influence over the bank. DT Marks’ commitment is signed by Eric F. Trump as president.
The OCC states that career staff reviewed the application and that the Comptroller and staff acted consistently with their statutory duties and ethical obligations.
The letter does not attribute the timeline to any particular factor.
The Criticism the Timeline Sits Against
The approval drew immediate accusations of favorable treatment. Senator Elizabeth Warren has described the preliminary approval as the most brazen act of self-dealing the US financial system has seen, as noted in our earlier reporting.
Warren wrote to Gould in January asking the OCC to commit in writing to pausing its review until Trump and his family divested, calling the process a sham. In May, she challenged the legal basis of the wider charter program, writing that the agency had approved at least nine national trust charters for crypto companies that appeared to go beyond what the statute permits.
According to the OCC report, they have approved 22 charter applications in the first 19 months of the current term, more than the total for the previous five years combined, and roughly 40 companies have applied since the start of 2025.
Where the OCC Has Said No
The agency’s first public denial of the current wave came three weeks before the World Liberty approval.
In Corporate Decision #1381, dated July 21, the OCC denied Wise US Holdings’ application to charter Wise National Trust in Austin, Texas. The letter states the OCC cannot conclude the proposed bank would have an effective AML/CFT compliance program while existing deficiencies remain unresolved.
The letter records that Wise US became subject to a public Multistate Consent Order on July 9, 2025, less than a month after the application was filed, identifying deficiencies in processes for investigating and reporting suspicious activity, transaction monitoring data integrity, and timely filing of suspicious activity reports.
Senior Deputy Comptroller Stephen A. Lybarger—the same official who signed the World Liberty approval—wrote that proposed leaders had demonstrated a persistent inability to sufficiently manage money-laundering and illicit finance risks, and that organizers collectively failed to demonstrate sufficient experience with banking laws related to fiduciary activities.
What Comes Next
World Liberty’s approval remains preliminary and conditional. The bank must raise $20 million in tier 1 capital, hold 180 days of operating expenses separately in Eligible Liquid Assets, and meet preopening requirements before commencing business, as The Crypto Times reported on August 15. The approval expires if capital is not raised within 12 months or the bank does not open within 18.
The OCC has also reported an eightfold rise in digital asset charter activity, with GENIUS Act implementation rules due before November.
The Crypto Times contacted the OCC at 11:14 am UTC to ask what accounted for the 220-day timeline and whether the volume of public comment extended the review.
The OCC declined to confirm the filing date, to explain the length of the review, or to address the discrepancy in its own decision document.
A spokesperson said the agency does not comment on licensing applications beyond what is posted on its website and referred The Crypto Times to its Corporate Applications Search. The spokesperson said the process under Comptroller Jonathan Gould is apolitical and nonpartisan and that the agency seeks to decide within 120 days of receiving a complete application or as soon as possible thereafter. The OCC does not publish statistics on its review of charter applications.
The 120-day target runs from receipt of a complete application rather than from filing. The OCC did not say when the World Liberty application was deemed complete.
Updated August 27, 2026, 11:16 am UTC: This article has been updated with a response received from the OCC after publication.
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