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OCC sent Zerohash's trust bank application back. The company didn't mention it until asked.

The OCC returned Zerohash's national trust bank application on July 17 as materially deficient, and the Morgan Stanley infrastructure provider says it will refile this month with a narrower scope.

Zerohash, the Chicago firm that runs crypto backend operations for Morgan Stanley's E*Trade, is not getting a national trust bank charter on its first try. The Office of the Comptroller of the Currency returned the company's application on July 17, according to OCC records reported by CoinDesk on Wednesday. The records don't state a cause.

A return is not a denial. Under OCC policy, the agency ends the process this way when a filing is "materially deficient" — missing required information on a company's finances or officers, or, per the agency's own June explanation of its procedures, when a filer's responses to an additional-information request "do not sufficiently respond to the requests." That explanation was published roughly a month before Zerohash's filing came back. Denials, which is what Wise and Bunq received, come with reasoning attached. Returns don't.

Zerohash told CoinDesk the return "is an administrative process that allows us to refile this month," that it "was taken in coordination with the OCC and is not a substantive decision on the merits," and that current operations under existing approvals are unaffected. The company is already a state-chartered trust bank. A person familiar with its operations told CoinDesk the E*Trade business does not depend on a federal charter. The OCC did not respond to CoinDesk's questions; Morgan Stanley declined to comment.

The original application, filed in March, covered "a wide range of digital asset and fiduciary services," the company said. The refiling will be "sequenced," starting with "a more focused approval of national trust activities."

Key facts

  • Application returned July 17, 2026 — OCC records, via CoinDesk.
  • Filed March 2026, during the post-GENIUS Act charter rush — CoinDesk.
  • Wise and Bunq were denied outright; Zerohash was returned — CoinDesk.
  • The Independent Community Bankers of America objected in April, citing "eleven filings or approvals in under one hundred days in some windows" involving Circle, Ripple, Paxos, BitGo, Fidelity Digital Assets, Crypto.com, Payoneer and Zerohash — ICBA letter.
  • Zerohash was seeking investment at a valuation above $1.5 billion in May, sources told CoinDesk — while the application was still live. Acquisition talks with Mastercard fell through.
  • Former chief compliance officer Edgar Guerra, ex-Federal Reserve, alleges in a California wrongful-termination suit that he and his staff identified more than 200 significant compliance gaps, including in anti-money-laundering controls. The company's push to force arbitration was preliminarily rejected. Zerohash declined to comment on the case.

The real-world read

Three things don't sit flush. First, Zerohash announced the filing publicly and said nothing when it came back — the July 17 return surfaced through OCC records, not the company. Second, "not a substantive decision on the merits" is the company's characterization; the OCC's published standard for a return is material deficiency, and the agency isn't confirming the "coordination" framing. Third, the company kept advertising jobs — a national trust officer, a chief operating officer — at a "Zerohash National Trust Bank" with a "pending charter application," and co-president Stephen Gardner's LinkedIn still lists him as CEO of that entity. Narrowing the scope on refiling is itself a concession that the first ask was too broad.

Unsaid: whether the OCC knew of, or weighed, the Guerra allegations. Nobody has said either way.

Opinion, and whose

The ICBA's view — that the charter pace "precludes deliberate, transparent policymaking" — is the community-bank lobby's, and that group has a competitive interest in slowing crypto entrants. Zerohash's expectation of "swift review" is the company's own forecast, not a regulator's commitment. Guerra's 200-plus compliance gaps are untested allegations in active litigation.

Sources

  • CoinDesk (Aug. 12, 2026), "Morgan Stanley's infrastructure partner Zerohash rebuffed in pitch to be U.S. trust bank" — the reporting throughout, citing OCC records for the July 17 return date, the company's written statement, OCC policy on returns, the ICBA's April objection letter, and unnamed sources on the valuation and Mastercard talks. No primary OCC statement was obtained. None of the material here is sponsored or promotional; the company statement is an interested party's account of its own filing and is treated as such.

Not financial advice.