Block's proposed bank has no branches, no deposits and no Jack Dorsey

Every headline about this attached Jack Dorsey's name to it. The filing does not.

Block has applied to the Office of the Comptroller of the Currency for a national trust bank charter, the company said on Tuesday 8 September 2026. Builders Bank & Trust would be uninsured and non-depository. It takes no deposits, makes no loans, and exists to custody bitcoin and other digital assets, execute customer orders on a riskless principal basis, and settle stablecoins.

Dorsey is not among the organisers, the directors or the senior executives. He appears only as Block's co-founder. The chair and chief executive would be Lee Woolley, Block's digital asset strategy lead, previously of Northern Trust and BNY Mellon. Two custodians, which tells you what this bank is for.

There is a better detail than that one. Builders Bank would be headquartered in Sioux Falls, South Dakota, with no branches, and all five proposed directors live somewhere else. Block has asked the regulator to waive the rule requiring one of them to live within 100 miles of it.

A national bank whose board cannot reach it in under two hours. Who exactly is expected to walk in? (South Dakota is where trust charters go for the trust law, not for the weather.)

Strip the vocabulary and this is a licensing trade

Block has run digital asset services for about eight years under more than 50 state money transmitter and virtual currency licences, moving roughly $10.7 billion of bitcoin volume in 2025 and serving about two million monthly crypto users through Cash App by the second quarter.

Fifty-odd examinations. Fifty-odd renewal calendars. Fifty-odd interpretations of the same activity.

And one federal charter replaces the lot, and if you have ever watched a payments company staff a state-licensing team you know roughly what that is worth. Block's own phrasing is that it wants "a consistent national framework as the business scales", which is what a compliance officer says when they mean the map is the problem.

So how hard is the charter to get?

So: harder than nothing, and easier than the coverage implies. The Block reports that since 2025 the regulator has received 40 de novo charter applications, approved 21 and denied two. Twenty-three decided, then, which is an approval rate above ninety percent, with 17 still in the queue. The one public denial this year was Wise National Trust, in July.

Which makes a charter less a seal of approval than a place in line.

The honest case against our reading is a textual one

Senator Elizabeth Warren has argued that the agency lacks the authority to grant trust charters to firms doing no traditional fiduciary work, and she has a point about the words.

In April the regulator amended its chartering rule to cover "operations of a trust company and activities related thereto" rather than "fiduciary activities", which is the exact wording Block's application leans on, while saying the change neither expands nor contracts its authority. Read that last clause again and decide whether you believe it.

But we would say the rewrite is doing real work, that somebody will litigate it eventually, and that this queue will have cleared long before they do.

The risk to the pipeline is political, not prudential

Our read is that Builders Bank gets conditional approval within nine months. Sitting in the same list are Morgan Stanley, Zerohash, Payoneer, Kraken's Payward, whose parent took $100m from Nasdaq and bought its surveillance software on the same day, and the Trump-linked World Liberty Financial.

A charter regime that approves better than nine in ten of the applications it decides will eventually approve something that turns the whole regime into a campaign issue. A denial of a large, well-capitalised applicant on fiduciary-purpose grounds would tell us the agency is drawing a line we cannot currently see.

One last thing, offered without comment. The bank will settle stablecoins, and Dorsey has said publicly that he does not much like stablecoins and would rather build on Bitcoin. Filed on 4 September, announced on the 8th.

Somebody won an argument in between.