Alaska permits crypto-related activity under its existing money transmission license, allowing companies to engage in digital asset custody, exchange, and transfer services without obtaining a separate charter. While not a dedicated crypto framework, this regulatory interpretation enables non-bank entities to operate legally in the state with digital assets under the oversight of the Alaska Division of Banking and Securities. As of January 1, 2023, Alaska eliminated its previous Limited Licensing Agreement (LLA) system and now requires all virtual currency transmitters to apply for a full money transmission license, ensuring consistent supervision under the state’s existing regulatory structure

Industrial Loan Company (ILC) - Inactive

California permits the chartering of Industrial Loan Companies (ILCs) under state law, though new issuances are rare. ILCs in California can engage in limited banking activities such as lending and issuing loans, and may accept deposits if FDIC-insured. While the charter remains legally active, the state has taken a cautious regulatory posture, and few new ILCs have been approved in recent years, making California a low-activity but permissive ILC jurisdiction.

Industrial Loan Company (ILC) - Inactive

Colorado permits Industrial Loan Companies (ILCs) under state law, though the charter is seldom used in practice. While authorized, no significant ILC activity has occurred in recent years, and the state has not positioned itself as a hub for charter innovation in this area. As a result, Colorado is considered a permissive but inactive ILC jurisdiction, offering legal support for ILCs without an active chartering pipeline.

Innovation Bank - Active

Connecticut offers a special-purpose Innovation Bank charter under Section 36a-70(t) of the Connecticut General Statutes. This charter allows entities to conduct wholesale or merchant banking activities without accepting retail deposits or requiring FDIC insurance. Innovation banks have the same powers and are subject to the same prudential standards as FDIC-insured state banks—except they are exempt from community reinvestment requirements and prohibited from retail deposit-taking. This makes Connecticut a pioneering state for non-bank financial institutions seeking a regulated, limited-purpose banking charter.

Merchant Acquirer Limited Purpose Bank (MALPB) - Active

Georgia offers a unique special-purpose charter known as the Merchant Acquirer Limited Purpose Bank (MALPB). This charter is designed specifically for payment processors and merchant acquirers, allowing them to operate as limited-purpose banks under state supervision. MALPBs may engage in activities such as settlement, clearing, and acquiring of payment card transactions, but they cannot accept deposits and are not FDIC-insured. Georgia is the only state to offer this charter type, making it a specialized regulatory option for firms operating in the payments infrastructure ecosystem.

Industrial Loan Company (ILC) - Inactive

Hawaii permits the chartering of Industrial Loan Companies (ILCs) under state law, though actual chartering activity is minimal. ILCs are legally authorized to engage in limited banking functions such as lending and certain deposit activities (if FDIC-insured), but the state has seen little recent use of this charter type. As a result, Hawaii is considered a statutorily permissive but inactive ILC jurisdiction, with limited traction among fintechs or non-bank firms.

Uninsured Bank - Status Unclear

Idaho has explored the use of uninsured, non-lending, 100% reserve bank charters through its state regulatory framework. In 2022, the Idaho Department of Finance granted preliminary approval for PayService Bank, a proposed institution that would operate without FDIC insurance, maintain full reserve backing, and abstain from lending—positioning it as a novel model for infrastructure-focused or fintech-aligned banking. However, the approval was later revoked when PayService failed to meet the operational and capitalization conditions required by the state. While Idaho does not have a formalized statutory category like Vermont’s investor-owned uninsured bank, this case signals the state’s willingness to consider non-traditional banking models, albeit with a high bar for execution and compliance.

Industrial Loan Company (ILC) - Inactive

Indiana permits the chartering of Industrial Loan Companies (ILCs) under state law and has historically issued ILC charters, though recent activity has been limited. The charter remains legally active, allowing non-bank entities to engage in consumer and commercial lending, often without triggering full bank holding company regulation. While not a major ILC hub today, Indiana is considered a permissive jurisdiction with a dormant but viable ILC framework.

Mutual Bank - Active

Massachusetts offers a Mutual Bank charter, a legacy institution type that remains actively used in the state. Mutual banks are depository institutions owned by their depositors, rather than shareholders, and are often community-focused with a strong emphasis on local lending and customer service. Massachusetts is one of the few states where mutual banks are still chartered and maintained at scale, making it a notable jurisdiction for mutual ownership banking models. These institutions are regulated by the Massachusetts Division of Banks and may also hold FDIC insurance.

Industrial Loan and Thrift Company (ILTC) - Inactive

Minnesota permits Industrial Loan and Thrift Companies (ILTCs)—a variant of Industrial Loan Companies (ILCs)—under state law. These institutions may engage in lending and credit activities, and some may accept deposits if they obtain FDIC insurance. While the charter is statutorily active, Minnesota has seen little recent chartering activity, especially among non-bank entrants. As such, it is considered a permissive but quiet ILC jurisdiction, with a legacy framework that could be leveraged for fintech or credit-focused innovation.

Digital Asset Depository Institution (DADI), Crypto-enabled Trust Company - Active

Nebraska offers a Digital Asset Depository Institution (DADI) charter under the Nebraska Financial Innovation Act of 2021. This special-purpose state bank charter is designed for firms engaged in digital asset custody, exchange, and stablecoin-related activities. DADIs must maintain full reserve backing, are prohibited from lending, and may operate without FDIC insurance. They are regulated by the Nebraska Department of Banking and Finance and are eligible to apply for a Federal Reserve master account. Nebraska’s DADI framework positions it as a leading state for digital asset banking innovation, comparable to Wyoming’s SPDI charter. Nebraska also permits Crypto-enabled Trust Companies, allowing firms to offer digital asset custody and fiduciary services under a state trust charter. These entities operate under the supervision of the Nebraska Department of Banking and Finance and may serve as custodians for tokenized assets, digital securities, or crypto assets. This dual-track approach—with both DADI and crypto-enabled trust options—makes Nebraska one of the most flexible states for chartering regulated digital asset institutions.

Industrial Loan Company (ILC), Limited-Purpose Trust Company, Crypto-enabled Trust Company - Active

Nevada offers a flexible chartering environment that supports Industrial Loan Companies (ILCs) and Limited-Purpose Trust Companies, both of which can be structured for digital asset and fintech use cases. The state has permitted crypto-enabled trust companies to operate under its trust statute, providing regulated pathways for custody, tokenization, and fiduciary services.

Limited-Purpose Trust Company, BitLicense - Active

New York offers one of the most established regulatory frameworks for special-purpose financial institutions, particularly those focused on digital assets. Through the New York Department of Financial Services (NYDFS), the state charters Limited-Purpose Trust Companies that allow firms to engage in custody, settlement, and token issuance. NYDFS also issues the BitLicense, a separate regulatory regime for virtual currency businesses, often held alongside a trust charter. This dual-licensing model has been used by major firms like Coinbase, Gemini, and Paxos, positioning New York as a leading jurisdiction for crypto-regulated institutions with access to fiduciary powers and compliance credibility.

Non-depository Trust Company, Crypto-enabled Trust Company - Active

South Dakota is a leading jurisdiction for non-depository trust companies, offering a streamlined and business-friendly charter for institutions providing custody, fiduciary, and wealth management services. The state has also become a hub for crypto-enabled trust companies, allowing digital asset custodians to operate under its trust framework with relatively light regulatory friction. South Dakota’s legal and tax environment, combined with its privacy protections and regulatory clarity, make it a preferred destination for both traditional trust services and digital asset custody platforms.

Crypto-enabled Trust Company - Active

Tennessee offers a state trust company charter that has been explicitly modernized to accommodate digital asset custody and fiduciary services. Recent legislative updates clarify that trust companies may hold and manage virtual currencies and other digital assets, positioning Tennessee as a crypto-forward jurisdiction within a traditional regulatory framework. The state does not offer a special-purpose digital asset bank, but its trust charter is actively used by crypto custodians, making it a practical and accessible option for fintechs seeking regulated custody capabilities.

Crypto-enabled Trust Company - Active

Texas offers a state trust company charter that supports crypto-enabled fiduciary services, making it one of the earliest states to formally recognize digital asset custody within a traditional trust framework. Guidance from the Texas Department of Banking affirms that state-chartered trust companies may safekeep virtual currencies as part of their custodial duties. While Texas does not have a dedicated digital asset bank charter, its clear regulatory posture, large financial market, and legal certainty have made it a strategic choice for crypto custodians and fintechs seeking state oversight without deposit-taking authority.

Industrial Loan Company (ILC) - Active

Utah is the most active and prominent jurisdiction for Industrial Loan Companies (ILCs), offering a unique state bank charter that permits lending and deposit-taking—often without triggering Bank Holding Company Act (BHCA) supervision. This has made Utah a national hub for fintechs, commercial firms, and specialty finance companies seeking regulated access to banking functions. ILCs in Utah are FDIC-insured and regulated by both the Utah Department of Financial Institutions and the FDIC, with notable examples including firms like Square Financial Services. Utah’s mature ILC framework and regulatory support make it the leading state for non-bank-affiliated ILC charters.

Investor-Owned Uninsured Bank - Active
Business Development Bank - Inactive

Vermont offers two special-purpose banking charters for non-depository institutions: the Investor-Owned Uninsured Bank and the Business Development Bank. The Investor-Owned Uninsured Bank, authorized under 8 V.S.A. § 12604, is an active framework that permits the creation of FDIC-uninsured institutions owned by private investors. These entities can engage in specialized financial services without accepting retail deposits. Acceleron Bank reports being in the final stages of securing their banking license in the state of Vermont. In contrast, the Business Development Bank charter—designed to support mission-driven lending in underserved areas—remains rarely used, with no recent activity, making Vermont’s uninsured bank statute the more relevant pathway for financial innovation.

Special Purpose Depository Institution (SPDI), Crypto-enabled Trust Company - Active

Wyoming is a national leader in charter innovation, offering the Special Purpose Depository Institution (SPDI)—a first-of-its-kind state bank charter tailored for digital asset custody, settlement, and tokenization. SPDIs are non-lending, must maintain 100% reserve backing, and may apply for a Federal Reserve master account, though FDIC insurance is not required. Regulated by the Wyoming Division of Banking, SPDIs are designed to bridge the gap between blockchain-based finance and traditional financial infrastructure. Wyoming also permits crypto-enabled trust companies, making it one of the most comprehensive and forward-looking jurisdictions for regulated digital asset institutions.