Independent trust companies
Non-depository trust companies act as trustee, custodian, and estate or account administrator for families, retirement plans, and institutions without taking deposits or making loans. They hold a state trust charter or an OCC national trust bank charter and earn fees on the assets they administer.
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ActivePrivate equity and large platforms are buying trust companies now, but hundreds of small state charters remain and new ones keep forming.
- Fragmentation
- High
- Charters are spread across many states and most firms are small, while assets concentrate in a few large names.
- Universe from a public registry
- Medium
- State banking departments publish charter lists, but there is no single national list and the lists mix family and public trust companies.
- Recurring revenue
- High
- Fees are charged annually on administered assets and regulators describe the income as recurring.
- Change-of-control friction
- Medium
- Every deal needs prior regulator approval in each chartering state or from the OCC, but the process is routine and published approvals show it working.
- AI operating leverage
- High
- Salaries are the largest expense and much of the work is reading documents and applying fiduciary rules.
Our view. For change-of-control friction, High means harder to close.
Universe
Registry
FFIEC National Information Center (NIC) plus state banking department charter lists. NIC lists OCC national trust banks and trust companies that report to federal agencies. Firms supervised only by a state are best found on each state’s charter list (for example South Dakota, Nevada, Delaware, New Hampshire and Wyoming), and those lists mix private family trust companies with public ones.
The OCC said in January 2026 that it supervises approximately 60 national trust banks. Most of them are uninsured.
Source: Office of the Comptroller of the Currency, Federal Register, Jan 12, 2026
South Dakota had 115 chartered trust companies at the end of 2024 after five surrendered charters that year. Assets held in South Dakota trusts rose from $680 billion to $815 billion during 2024.
Source: KELOLAND News (via Yahoo News), May 14, 2025; South Dakota Public Broadcasting, May 28, 2025
Delaware's bank commissioner supervised 36 state-chartered limited purpose and nondeposit trust companies at year-end 2024.
Source: Delaware Office of the State Bank Commissioner, Oct 2025
New Hampshire's Banking Department listed 26 trust company institutions on its website as of October 2026. It also charters three family trust companies.
Source: New Hampshire Banking Department
Diligence risks
Exam quality varies. In 2024 six South Dakota trust companies received less than satisfactory ratings and 16 were not rated.
Charter rules are contested. State supervisors said in December 2025 that they will scrutinize pending and future OCC national trust charter applications.
Assets often follow the referring adviser, attorney, or family rather than the trust company, so key-relationship loss after a sale is a real risk. Buyers should also diligence legacy fiduciary claims, crypto or alternative asset custody, and minimum capital rules in each state.
Our view
Fragmentation
South Dakota's October 2026 charter list splits its trust companies into private trust company and public trust company licenses.
New entrants keep arriving. South Dakota's August 2026 activity report listed several pending applications to establish new nondepository public trust companies.
Most charters are small firms with one or two offices that serve a single family, a wealth adviser, or a niche such as IRA custody. Fiduciary assets concentrate in a few large bank-affiliated and national firms, so the long tail is wide but thin.
Our view
Revenue model
The FDIC's trust examination manual says fees charged to trust accounts are usually the primary component of direct trust revenue. It says these fees are often based on the size, or market value, of the account.
The FDIC describes fiduciary fee income as recurring and often less volatile than interest income.
Revenue moves with market values because fees are asset-based. Directed trust work, where an outside adviser manages the investments, earns a lower administrative fee than full discretionary trusteeship.
Our view
Change of control
Buying control of a national trust bank requires prior written notice to the OCC under its change in control rule.
Source: Legal Information Institute, Cornell Law School, Oct 2026
Nevada requires anyone who intends to acquire control of a retail trust company to apply to the state Commissioner. Control includes a change in ownership of at least 25 percent of voting stock.
Source: Nevada Legislature, Apr 2026
A platform with charters in several states needs approval in each one, and the buyer's owners and managers face fitness reviews. Trust accounts usually stay with the acquired charter, but co-trustees, trust protectors, and directing advisers can often move accounts if they dislike the new owner.
Our view
Who is consolidating
No aggregate evidence is shown for this section.
Where AI changes the cost base
Labor is the main cost. The FDIC says salaries are likely the largest direct expense in most trust operations.
Rules require recurring account reviews. A national trust bank must review all assets of each fiduciary account where it has investment discretion at least once every calendar year.
Trust administration is document heavy. Staff read trust instruments, process distribution requests, prepare fiduciary tax filings, run KYC and AML onboarding, and write account review memos, and much of this can be drafted or checked by software.
Our view
Discretionary decisions carry personal fiduciary liability, so a trust officer must still review and sign off. The gain is in faster preparation and checking, not in removing the officer.
Our view
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