Summary

The OCC's June 18 conditional approval for Morgan Stanley Digital Trust (MSDTNA) includes 11 pre-opening requirements plus 6 ongoing conditions. The trust must maintain $50M tier 1 capital (50% in eligible liquid assets) and 180 days of operating expenses in liquid assets for the first 3 years. The application was filed Feb 18, 2026 — approval took exactly 4 months.

Key Points

• $50M minimum tier 1 capital for first 3 years; at least 50% ($25M) in Eligible Liquid Assets
• 180 days of operating expenses in Eligible Liquid Assets (separate from capital requirement)
• Quarterly capital/liquidity assessment required for first 3 years
• OCC non-objection required for any significant business plan deviation or senior executive/director appointments
• Independent external auditor required annually for at least 3 years
• Trust will custody digital assets, facilitate staking on fiduciary basis, act as collateral administrator for digital asset lending
• Supports Morgan Stanley's Zerohash partnership for crypto trading on E*Trade
• One comment received from a bank trade group questioning OCC authority — dismissed by OCC

Sources

• OCC Corporate Decision #1378 (Official PDF)
• Banking Dive