The OCC finalized rules effective April 1 allowing national trust banks to engage in non-fiduciary activities like digital asset custody. Over 10 fintechs have received conditional approvals. More are coming, allowing them to operate nationwide under a single federal regulator without full deposit insurance or CRA obligations. The real threat is not that community banks will lose custody business because most were never in that business. The threat is that these fintechs become the on-ramp for payments and deposits, so customers never need your transaction account at all. A fintech trust bank can offer direct deposit, bill pay, and crypto services without the customer ever stepping foot in a community bank.
What you should do: Focus on what these fintechs cannot offer: FDIC insurance on large balances, small business lending relationships, local decision-making, and the trust that comes from a recognizable local institution.
Final rule: https://www.occ.treas.gov/news-issuances/bulletins/2026/bulletin-2026-4.html