8 years
Time Block has operated digital asset services under more than 50 state licenses 2
$10.7 billion
Bitcoin transaction volume managed by Block in 2025 2
2 million
Monthly active cryptocurrency users served through Cash App by the second quarter 2
5
Proposed directors for Builders Bank & Trust, all residing outside South Dakota 2

The Charter Application and Proposed Structure

Block Inc., the parent company of Square, Cash App, and Bitkey, has submitted an application to the Office of the Comptroller of the Currency (OCC) to establish a national trust bank named Builders Bank & Trust, N.A. 12. The application was announced in September 2026, with reports differing on whether the announcement occurred on Tuesday or Wednesday 12. If approved, the new entity would operate as a federally regulated national trust bank under OCC supervision 1.

Unlike traditional commercial banks, Builders Bank & Trust is designed to be an uninsured, non-depository institution 2. This means the bank will not accept customer deposits or issue loans 2. Instead, its primary business operations will focus on the custody of Bitcoin and other digital assets, executing customer buy and sell orders on a riskless principal basis, and facilitating stablecoin settlement 2.

The proposed bank would be headquartered in Sioux Falls, South Dakota, with no branches 2. Block has asked the OCC to waive the residency rule requiring at least one of its five proposed directors to live within 100 miles of the headquarters, as all currently reside elsewhere 2.

Leadership and Corporate Strategy

Builders Bank & Trust will be led by Lee Woolley, Block's digital asset strategy lead and former Northern Trust and BNY Mellon executive 2. Woolley will serve as chairman, president, and CEO 12. He stated that Builders Bank is well positioned to support Block's vision of economic empowerment, leveraging the firm's digital asset experience, Square Financial Services history, and the team's banking expertise 1.

Block's co-founder and CEO, Jack Dorsey, is not among the bank's organizers, directors, or senior executives, appearing in the filing only as co-founder 2. Dorsey, a Bitcoin maximalist, has expressed dislike for stablecoins, preferring to build on Bitcoin 2. Thus, the bank's plan to support stablecoin settlement represents a potential strategic compromise 2.

The transition to a federal charter represents an effort by Block to consolidate its regulatory framework 2. The company has operated digital asset services for eight years under more than 50 state licenses 2, managing $10.7 billion in Bitcoin volume in 2025 and serving two million monthly crypto users through Cash App by the second quarter 2. A federal charter would let it support these activities under a consistent national framework as the business scales 2.

Regulatory Context and Industry Precedents

Block's application comes amid a shifting regulatory landscape. The OCC conditionally approved five crypto trust charters last December (Circle, Ripple, BitGo, Fidelity Digital Assets, and Paxos) 2, and three more in February (including Crypto.com and Stripe's Bridge) 2. Coinbase received preliminary approval in April 2.

Reports conflict regarding World Liberty Financial, a protocol backed by Donald Trump 12. One source states it received approval this year, while another lists it on the OCC's pending list alongside Morgan Stanley, Payoneer, Zerohash, and Kraken's Payward 12.

Securing a charter is not guaranteed; the OCC denied Wise National Trust in July 2. In April, the OCC amended its chartering rule to cover 'operations of a trust company and activities related thereto' instead of 'fiduciary activities' 2. Senator Elizabeth Warren has argued the OCC lacks authority to grant trust charters to firms not performing traditional fiduciary work, a reading the industry disputes 2.

What is not yet established

  • The exact capital figures and business plan details for Builders Bank & Trust, which were submitted as confidential exhibits 2.
  • Whether the OCC will approve Block's request to waive the residency requirement for its proposed board of directors 2.
  • The final regulatory status of World Liberty Financial, given conflicting reports on whether it has received approval or remains on the pending list 12.
  • Whether the OCC will ultimately approve Block's application, especially in light of political opposition and the recent denial of other trust charter applications 2.

Frequently asked questions

What services would Builders Bank & Trust provide if approved?

It would custody Bitcoin and other digital assets, execute customer orders on a riskless principal basis, and settle stablecoins 2. As an uninsured, non-depository trust bank, it would not accept deposits or make loans 2.

Why is Block applying for a federal trust charter instead of continuing with state licenses?

Block has operated for eight years under more than 50 state licenses 2. It says a federal charter would allow it to support these activities under a consistent national framework as the business scales 2.

Is Jack Dorsey directly involved in running the proposed bank?

No, Dorsey is not an organizer, director, or executive of the bank, appearing only as Block's co-founder 2. The bank's plan to support stablecoins also contrasts with his preference to build on Bitcoin 2.

Sources

  1. Bitcoin Magazine — Jack Dorsey’s Block Becomes Latest Bitcoin-Focused Company To Apply for Banking Charter (2026-09-09) https://bitcoinmagazine.com/news/block-applies-for-banking-charter
  2. Decrypt — Jack Dorsey's Block Applies for Bank Charter to Custody Bitcoin (2026-09-09) https://decrypt.co/377746/jack-dorseys-block-applies-for-bank-charter-to-custody-bitcoin

This brief is for information and education. It is not financial advice or a recommendation to buy or sell.