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Block Already Custodies Its Customers' Bitcoin for Free. Its New Bank Is Not for Them.

Block applied to charter Builders Bank for bitcoin custody. It already holds that bitcoin free: a $1.41bn book, worth $3.5M a year at a named fund's fee.

A bank with no deposits, no loans, no published rate and no published book

Block's OCC application for Builders Bank & Trust, N.A., filed 8 September 2026

Builders Bank, as applied forThe figure
Deposits and loansNeither — ruled out
Revenue it is left withCustody and fiduciary fees
Published fee rate or target bookNone
Customer bitcoin held, last disclosed$1.41bn at 30 Sep 2024
Fee on that at 0.25%$3.5M a year
Bitcoin line gross profit, Jun-26 qtr$72M
Assets needed to match it at 0.25%$115bn

The exclusions and the absence of a fee schedule or assets-under-custody target are from Block's September 8 investor release; Block has published neither. The $1.41bn is the safeguarding balance for customer bitcoin Block last disclosed, at 30 September 2024, before an accounting change removed the line from its balance sheet — there is no more recent figure. The 0.25% rate is the published sponsor's fee of the iShares Bitcoin Trust, used as a named comparable; it is not Block's rate. The fee and required-assets figures are R40 arithmetic on those inputs. Bitcoin Ecosystem gross profit is as Block reported for the June 2026 quarter.

To match the gross profit Block's bitcoin line already earns, Builders Bank needs 81x the book Block last disclosed$bn of assets under custody — R40 arithmetic on published comparable fee ratesCustomer bitcoin Block last disclosedAssets it would still have to win037.575112.5150Held today (last disclosed) — Customer bitcoin Block last disclosed: 1.41.4Held today (last disclosed)Needed at 1.50% — Customer bitcoin Block last disclosed: 1.4Needed at 1.50% — Assets it would still have to win: 17.819.2Needed at 1.50%Needed at 0.25% — Customer bitcoin Block last disclosed: 1.4Needed at 0.25% — Assets it would still have to win: 113.8115.2Needed at 0.25%The base of every column is the $1.41bn safeguarding balance for customer bitcoin Block disclosed at 30 September 2024, its lastsuch disclosure. The targets are the assets under custody required to earn $288M a year in fees — the annualised run rate of the$72M of gross profit Block's Bitcoin Ecosystem line produced in the June 2026 quarter — at two published sponsor's fees used asnamed comparables: 0.25% (iShares Bitcoin Trust) and 1.50% (Grayscale Bitcoin Trust). Neither is Block's rate; Block haspublished none. Custody fees are not costless to earn, so treating fee revenue as gross profit makes these required-assetfigures a floor rather than a target.

Block said on 8 September it has applied to the Office of the Comptroller of the Currency to establish Builders Bank & Trust, N.A., an uninsured national trust bank for bitcoin and stablecoin custody. The release says it "would not accept deposits or make loans" — which removes net interest income, leaving fees for holding other people's assets — and that it "would not commence operations unless and until it receives the required regulatory approvals."

Block already does the job. Its June-quarter filing says it "allows its Cash App customers to store their bitcoin in the Company's digital wallets free of charge," holding the keys and the recordkeeping itself. So the question is not what a custody bank could earn but who it is for, and the last number Block published answers it. Under the SEC's old safeguarding rule it disclosed $1.41bn of customer bitcoin at 30 September 2024; the rule was rescinded in January 2025 and Block now recognises no such amount, so that stale figure is the only anchor anyone has. At iShares' published 0.25% sponsor fee it would yield about $3.5M a year1.2% of the roughly $288M annual gross profit run rate of Block's Bitcoin Ecosystem line, which turned $1,894M of revenue into $72M of gross profit in the June 2026 quarter.

A charter this small against the existing book is not a Cash App product. It is a regulated wrapper aimed at institutions who need a supervisor's name — which is checkable the moment Block publishes a fee schedule or an assets-under-custody target, and unfalsifiable until it does.


The application, the two quoted phrases and the 8 September date are from Block's announcement; the free-custody quote, the $1.41bn safeguarding balance at 30 September 2024 and the derecognition are from Block's own filings; the June-quarter segment figures are as reported, captured in our June-quarter notes. The 0.25% rate is iShares' published sponsor fee applied to a book Block has not updated in nearly two years — the yield is R40 arithmetic on a stale anchor, not a forecast.

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